STC.UNM v. Intel Corporation

Filing 126

Joint MOTION to Amend/Correct 100 Order on Motion to Amend/Correct - Unopposed Joint Motion to Amend Scheduling Order [Doc. No. 100] by STC. UNM. (Pedersen, Steven)

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UNITED STATES DISTRICT COURT DISTRICT OF NEW MEXICO STC.UNM, Plaintiff, v. INTEL CORPORATION, No. 10-CV-01077-RB-WDS Defendant. UNOPPOSED JOINT MOTION TO AMEND SCHEDULING ORDER [DOC. NO. 100] The parties hereby respectfully request the Court amend the deadlines for the claim construction briefing. Amendment of the Scheduling Order as proposed by the parties herein will not result in a delay in the timely disposition of this case and does not change the current fact or expert discovery cutoffs previously set by the Court. By requesting this amendment of the Scheduling Order, the parties are only requesting that the Court allow for an additional, short submission to accommodate briefing related to the depositions of the affiants that have submitted declarations in support of the parties’ claim construction briefs. Specifically, the parties request that the deadline of July 25th for the parties’ responsive claim construction briefs remain the same, but that the Court allow for an additional submission, no longer than 7 pages, on or before September 23rd., limited to issues raised for the first time in the Responsive Claim Construction Briefs or from the depositions. STC’s technical expert is currently teaching in New Zealand until the end of August, and is not available for deposition in the United States prior to the deadline for responsive briefs. The parties submit that the requested modification will provide the parties with the opportunity to depose the respective experts and to submit briefing on those depositions. 552534.01 Pursuant to D.N.M. LR-Civ. 7.1(a), this Motion is jointly made on behalf of all parties to this litigation and is unopposed. The parties agree that due to the above described logistical circumstances, good cause exists to amend the present deadlines for briefing of claims constructions. WHEREFORE, for the reasons set forth above, the parties respectfully request that the Court enter its Order amending the June 1, 2011 Scheduling Order [Doc. No. 100] and amend the deadlines for the parties’ claim construction briefs. Respectfully submitted, /s/ Steven R. Pedersen /s/ Brian L. Ferrall Deron B. Knoner, Esq. KELEHER & MCLEOD, P.A. PO Box AA Albuquerque, NM 87103 (505) 842-9150 Clifford K. Atkinson Douglas A. Baker Justin D. Rodriguez 201 Third St. NW, Suite 1850 Albuquerque, New Mexico 87102 (505) 764-8111 Rolf O. Stadheim, Esq. Joseph A. Grear, Esq. George C. Summerfield, Esq. Keith A. Vogt, Esq. Steven R. Pedersen, Esq. STADHEIM & GREAR, LTD. Robert A. Van Nest Brian L. Ferrall KEKER & VAN NEST LLP Chad S. Campbell Jonathan M. James Timothy J. Franks Mark E. Strickland Jonathan L. McFarland PERKINS COIE LLP Attorneys for Plaintiff STC.UNM Attorneys for Defendant Intel Corporation CERTIFICATE OF SERVICE The undersigned certifies that on the 14th day of July, 2011 the foregoing was filed electronically through the CM/ECF system, which caused all parties or counsel to be served by electronic means. /s/ Steven R. Pedersen Steven R. Pedersen 552534.01 2

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