Motorola Mobility, Inc. v. Apple, Inc.

Filing 203

Joint MOTION to Amend/Correct 113 Scheduling Order by Motorola Mobility, Inc.. Responses due by 1/3/2012 (Attachments: # 1 Text of Proposed Order)(Mullins, Edward) Modified link on 12/19/2011 (tp).

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
Case No. 1:10cv023580-Civ-RNS
MOTOROLA MOBILITY, INC.,
Plaintiff,
v.

JURY TRIAL DEMANDED

APPLE INC.,
Defendant.

APPLE INC.,
Counterclaim Plaintiff,
v.
MOTOROLA, INC. and
MOTOROLA MOBILITY, INC.,
Counterclaim Defendants.

JOINT MOTION FOR AMENDED SCHEDULING ORDER
Apple, Inc. (“Apple”) and Motorola Solutions, Inc. and Motorola Mobility, Inc.
(“Motorola”) (collectively, the “Parties”) jointly move the Court to amend its September 14,
2011 Order on Joint Motion for Amended Scheduling Order. (D.E. 113). In support of their
Motion, the Parties state that:
1.

This action involves claims by both Motorola and Apple for patent infringement

with respect to various patents.
2.

On February 1, 2011, the Court entered a Scheduling Order For Pretrial

Conference and Trial (“Scheduling Order”).
3.

On May 27, 2011, the Court modified the Scheduling Order and entered a

Modified Scheduling Order ("Modified Scheduling Order").

Case No. 1:10cv023580-Civ-RNS
4.

On September 12, 2011, the parties jointly proposed amending the case schedule

because of the timing of the Markman hearing, which was held from October 17-19, 2011,
before the Honorable Ursula Ungaro. (D.E. 111). The Court adopted the parties' proposed
schedule. (D.E. 113).
5.

The Court issued its Claim Construction Order on December 1, 2011. (D.E. 194).

6.

To accommodate additional time for fact and expert discovery, the parties jointly

propose further amending the case schedule as follows:

Deadline for the end of fact discovery
(interrogatories and requests for
admission)
Deadline for the end of fact discovery
(all other forms of discovery)
Opening expert reports
Rebuttal expert reports
Cutoff for expert depositions and
other expert-related discovery
Motions for summary judgment
7.

Current deadline
January 17, 2012

Proposed new deadline
January 17, 2012 (no
change)

January 17, 2012

February 10, 2012

January 27, 2012
February 24, 2012
March 23, 2012

February 17, 2012
March 16, 2012
April 13, 2012

April 6, 2012

April 20, 2012

The Parties’ proposal does not alter any other deadlines in the case.

WHEREFORE, the Parties respectfully request that the Court enter the proposed
Amended Scheduling Order, attached as Exhibit “A” hereto.
Dated: December 16, 2011

Respectfully submitted,

/s/ Edward M. Mullins
Edward M. Mullins (Fla. Bar No. 863920)
[e-mail]
Douglas J. Giuliano (Fla. Bar No. 15282)
[e-mail]
ASTIGARRAGA DAVIS MULLINS
& GROSSMAN, P.A.
701 Brickell Avenue, 16th Floor
Miami, Florida 33131
Telephone: [phone]
Facsimile: [phone]

/s/ Christopher R. J. Pace
Christopher R. J. Pace (Fla. Bar No. 721166)
[e-mail]
Edward Soto (Fla. Bar No. 265144)
[e-mail]
WEIL, GOTSHAL & MANGES LLP
1395 Brickell Avenue, Suite 1200
Miami, Florida 33131
Telephone: [phone]
Facsimile: [phone]

Attorneys for Motorola Mobility, Inc. and
Motorola Solutions, Inc.

Attorneys for Apple Inc.

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Case No. 1:10cv023580-Civ-RNS
Of Counsel:
Matthew D. Powers*
[e-mail]
Steven Cherensky*
[e-mail]
TENSEGRITY LAW GROUP LLP
201 Redwood Shores Parkway
Redwood Shores, CA 94065
Telephone: [phone]
Facsimile: [phone]

Of Counsel:
Mark D. Baker*
[e-mail]
Edward J. DeFranco*
[e-mail]
Alexander Rudis*
[e-mail]
QUINN EMANUEL URQUHART
& SULLIVAN, LLP
51 Madison Avenue, 22nd Floor
New York, NY 10010
Telephone: [phone]
Facsimile: [phone]

Mark G. Davis*
[e-mail]
WEIL, GOTSHAL & MANGES LLP
1300 Eye Street, N.W., Suite 900
Washington, DC 20005
Telephone: [phone]
Facsimile: [phone]

Charles K. Verhoeven*
[e-mail]
David A. Perlson*
[e-mail]
QUINN EMANUEL URQUHART
& SULLIVAN, LLP
50 California Street, 22nd Floor
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]

Robert T. Haslam*
[e-mail]
COVINGTON & BURLING LLP
333 Twin Dolphin Drive, Suite 700
Redwood Shores, CA 94065
Telephone: [phone]
Facsimile: [phone]

David A. Nelson*
[e-mail]
QUINN EMANUEL URQUHART
& SULLIVAN, LLP
500 West Madison Street, Suite 2450
Chicago, IL 60661
Telephone: [phone]
Facsimile: [phone]

Robert D. Fram*
[e-mail]
Christine Saunders Haskett*
[e-mail]
COVINGTON & BURLING LLP
One Front Street
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]

*Admitted pro hac vice
Attorneys for Motorola Mobility, Inc. and
Motorola Solutions, Inc.

*Admitted pro hac vice
Attorneys for Apple Inc.

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