AMERICAN EDUCATIONAL RESEARCH ASSOCIATION, INC. et al v. PUBLIC.RESOURCE.ORG, INC.

Filing 55

STIPULATION re Order JOINT STIPULATION AND [PROPOSED] ORDER EXTENDING COMPLETION DATE OF DEPOSITION OF PLAINTIFFS' EXPERT DR. PHILLIPS TO SEPTEMBER 22, 2015 by PUBLIC.RESOURCE.ORG, INC.. (Becker, Matthew)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
AMERICAN EDUCATIONAL RESEARCH
ASSOCIATION, INC., AMERICAN
PSYCHOLOGICAL ASSOCIATION, INC.,
and NATIONAL COUNCIL ON
MEASUREMENT IN EDUCATION, INC.,
Plaintiffs/Counterdefendants,
v.
PUBLIC.RESOURCE.ORG, INC.,
Defendant/Counterclaimant.

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Civil Action No. 1:14-cv-00857-TSC-DAR

JOINT STIPULATION AND PROPOSED ORDER TO EXTEND THE DATE ON
WHICH EXPERT DEPOSITION MAY BE TAKEN

STIPULATION
Counsel for Defendant Public.Resource.Org (“Public Resource”) and Plaintiffs American
Educational Research Association, Inc. (“AERA”), American Psychological Association, Inc.
(“APA”), and the National Council on Measurement in Education, Inc. (“NCME”) hereby enter
into the following Stipulation, and respectfully request the Court’s approval of the Proposed
Order.
1.

The parties stipulate that the deadline for the deposition of Plaintiffs’ expert

witness Dr. Phillips shall be extended to allow the deposition to be completed on September 22,
2015 in Phoenix, AZ.
2.

The parties agree that this deposition schedule allows the parties to conduct this

deposition in a reasonable manner while accommodating the witness’ and counsels’ various
schedules.
3.

Fact discovery in this action closed on May 18, 2015. The parties further agree

that the closing date for all other expert discovery to be taken in this action remains as September
11, 2015, as directed by the Court's Order of June 11, 2015 (Dkt. 53).
IT IS SO STIPULATED.

Dated: September 9, 2015

FENWICK & WEST LLP

By:

/s/ Matthew B. Becker
Andrew P. Bridges
Matthew B. Becker
DAVID HALPERIN
David Halperin
ELECTRONIC FRONTIER FOUNDATION
Corynne McSherry
Mitchell L. Stoltz
Attorneys for Defendant
PUBLIC.RESOURCE.ORG

Dated: September 9, 2015

QUARLES & BRADY LLP

By:

/s/ Jonathan Hudis
Jonathan Hudis
OBLON, MCCLELLAND, MAIER &
NEUSTADT, LLP
Kathleen Cooney-Porter
Katherine Cappaert
Attorneys for Plaintiffs
AMERICAN EDUCATIONAL RESEARCH
ASSOCIATION, INC., AMERICAN
PSYCHOLOGICAL ASSOCIATION, INC., and
NATIONAL COUNCIL ON MEASUREMENT
IN EDUCATION, INC.

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
AMERICAN EDUCATIONAL RESEARCH
ASSOCIATION, INC., AMERICAN
PSYCHOLOGICAL ASSOCIATION, INC. and
NATIONAL COUNCIL ON MEASUREMENT IN
EDUCATION, INC.
Plaintiffs/Counterdefendants,

Case No. 1:14-cv-00857-TSC-DAR
[PROPOSED] ORDER GRANTING
JOINT STIPULATION TO EXTEND
THE DATE ON WHICH EXPERT
DEPOSITION MAY BE TAKEN
(DKT. NO. 55)

v.
PUBLIC.RESOURCE.ORG, INC.,
Defendant/Counterclaimant.

Having fully considered the Joint Stipulation to Extend the Date on Which Expert
Deposition May Be Taken (Dkt. 55), and for good cause shown, it is hereby
ORDERED that the Joint Stipulation to Extend the Date on Which the Deposition of
Plaintiffs’ expert witness Dr. Phillips may be taken (Dkt. 55) is GRANTED, and it is further
ORDERED that the date by which the deposition of Plaintiffs’ expert witness Dr.
Phillips may be taken is extended to September 22, 2015, and it is further
ORDERED that the closing date for all other expert discovery to be taken in this action
remains as September 11, 2015, as directed by the Court's Order of June 11, 2015 (Dkt. 53).

Dated: _________________________

_________________________________
Hon. Deborah A. Robinson
United States Magistrate Judge