STC.UNM v. Intel Corporation

Filing 145

MOTION to Bifurcate and Early Trial on Damages by STC. UNM. (Pedersen, Steven)

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEW MEXICO
LAS CRUCES DIVISION
STC.UNM,
Plaintiff,
Civil No. 1:10-cv-01077-RB-WDS

v.
INTEL CORPORATION
Defendant.

PLAINTIFF'S MOTION FOR BIFURCATION
AND EARLY TRIAL ON DAMAGES
Plaintiff, STC.UNM, moves to bifurcate damages from liability for an early trial, prior
to the mandatory settlement conference, solely on the issue of damages. For the reasons
set forth in the accompanying memorandum, STC.UNM submits that the proposed
bifurcation will increase the likelihood of settlement, save the parties’ time and money,
and conserve Court resources. Pursuant to the Court’s authority under Fed. R. Civ. P.
42(b), STC respectfully requests that the motion be granted.
Counsel for STC conferred with counsel for Intel regarding the proposed bifurcation,
and was informed that Intel does not consent to the motion.

Dated: September 27, 2011

Respectfully submitted,
/s/ Steven R. Pedersen
Rolf O. Stadheim
Joseph A. Grear
George C. Summerfield
Keith A. Vogt
Steven R. Pedersen
STADHEIM & GREAR, LTD.
400 N. Michigan Avenue, Suite 2200
Chicago, Illinois 60611
[phone]

Deron B. Knoner
KELEHER & MCLEOD, P.A.
201 Third Street NW, 12th Floor
PO Box AA
Albuquerque, New Mexico 87103
[phone]

Attorneys for Plaintiff STC.UNM

CERTIFICATE OF SERVICE: The undersigned certifies that on the 27th day of
September, 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

2