Timebase Pty Ltd v. Thomson Corporation, The

Filing 226

MOTION for Extension of Time to Extend the Pretrial Schedule by Thirty Days by Thomson Corporation, The, West Publishing Corporation, West Services. (Wagner, Kevin)

UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
TIMEBASE PTY LTD.,

Civil No. 07-1687 (JNE/JJG)
Plaintiff,

vs.
THE THOMSON CORPORATION,
WEST PUBLISHING CORPORATION,
and WEST SERVICES, INC.,

UNOPPOSED MOTION TO
EXTEND THE PRETRIAL
SCHEDULE BY THIRTY DAYS

Defendants.

Pursuant to Local Rule 16.3, and for the reasons stated below, defendants The
Thomson Corporation, West Publishing Corporation, and West Services, Inc. move the
Court for leave to extend the remaining dates of the Pretrial Scheduling Order by
approximately thirty days. Plaintiff TimeBase Pty Ltd. does not oppose this motion. A
Proposed Order for such an extension is submitted herewith.
1.

Background to the Motion. Since the entry of the Court’s Order

Modifying Pretrial Scheduling Order dated February 1, 2011, the parties have worked
diligently to complete expert discovery. The parties have exchanged all expert reports
and have been working to schedule and complete expert depositions. Because
TimeBase’s experts in this case include the Chair of the Department of Computer
Sciences at Georgetown who holds academic appointments with supervisory, research,
and teaching responsibilities, the parties have been unable to schedule his deposition
within the current deadline on a date that works for Dr. Frieder and defendants’ counsel.

The parties are identifying workable dates in June for the academic experts so that these
depositions will be completed within an additional thirty-day period. Accordingly,
defendants request, and TimeBase does not oppose, that the Court approve a short
extension of thirty days for the remaining pretrial deadlines.
2.

Statement of Good Cause. Good cause exists to extend the current Pretrial

Scheduling Order deadlines by thirty days because the parties have been working
diligently to complete expert discovery and need a short extension of time in which to
accommodate the schedules of academic experts.
3.

Completed Discovery. The parties have completed all discovery except for

expert depositions.
4.

Discovery that Remains to be Completed. The only discovery that remains

to be completed are expert depositions.
5.

The Proposed Extension. A short thirty-day extension is requested for the

remaining pretrial deadlines as follows:
Event

Current Deadline

Requested Deadline

Expert Discovery Completed

May 20, 2011

June 20, 2011

Non-Dispositive Motions re: Expert
Discovery

May 20, 2011

June 20, 2011

Deadline for Filing Dispositive
Motions

June 1, 2011

July 1, 2011

Trial Ready

August 16, 2011

September 16, 2011

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Respectfully submitted,

Dated: April 25, 2011

s/Kevin P. Wagner
David J.F. Gross (# 208772)
Calvin L. Litsey (# 153746)
Mary V. Sooter (pro hac vice)
Kevin P. Wagner (# 34008X)
Katherine S. Razavi (#388958)
Faegre & Benson LLP
2200 Wells Fargo Center
90 South Seventh Street
Minneapolis, Minnesota 55402
[e-mail]; [e-mail];
[e-mail]; [e-mail];
[e-mail]; [e-mail]
Attorneys for The Thomson Corporation,
West Publishing Corporation,
And West Services, Inc.

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