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)

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
[phone]

Clifford K. Atkinson
Douglas A. Baker
Justin D. Rodriguez
201 Third St. NW, Suite 1850
Albuquerque, New Mexico 87102
[phone]

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

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