CROSS ATLANTIC CAPITAL PARTNERS, INC. v. FACEBOOK, INC. et al

Filing 66

STIPULATION to Continue Expert Report Deadlines and the Discovery Cutoff by FACEBOOK, INC., THEFACEBOOK, LLC. (KEEFE, HEIDI) (FILED IN ERROR BY ATTORNEY; COPY FORWARDED TO JUDGE FOR APPROVAL) Modified on 2/7/2008 (nd).

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CROSS ATLANTIC CAPITAL PARTNERS, INC. v. FACEBOOK, INC. et al Doc. 66 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA CROSS ATLANTIC CAPITAL PARTNERS, INC., Plaintiff, v. FACEBOOK, INC. and THEFACEBOOK, LLC, Defendants. CIVIL ACTION NO. 07-CV- 02768-JP JURY TRIAL DEMANDED STIPULATION TO CONTINUE EXPERT REPORT DEADLINES AND THE DISCOVERY CUTOFF WHEREAS, the Court has postponed the claim construction hearing by two weeks from January 25, 2008 to February 8, 2008; and WHEREAS, the parties desire that their respective experts consider the Court's claim construction in rendering their opinions concerning infringement and validity; and WHEREAS, the parties agree that a corresponding two week extension of expert report deadlines and the discovery cutoff would be beneficial; NOW THEREFORE, the parties, through their respective counsel, hereby stipulate, and respectfully request that the Court order, as follows: The date for the service of the information referred to in Federal Rule of Civil Procedure 26(a)(2)(B) by expert report, deposition or answer to expert interrogatory on issues for which that party bears the burden of proof shall be continued from February 25, 2008 to March 10, 2008. The date for service of evidence intended solely to contradict or rebut evidence on the same subject matter identified by another party shall be continued from March 10, 2008 to PALOALTO 86273 v1 (2K) Dockets.Justia.com March 24, 2008. The deadline for all requests for and responses to discovery to be served, noticed and completed shall be continued from March 26, 2008 to April 9, 2008. The Court's Federal Rule of Civil Procedure 16 Pretrial Scheduling Order entered on October 12, 2007 (Doc. 36), remains in full effect in all other respects. Respectfully submitted, By: /s/ Patrick J. Keenan Patrick J. Keenan, Esq. pjk@duffykeenan.com Duffy & Keenan One Liberty Place 1650 Market Street, 55th Floor Philadelphia, PA 19103-7301 Frederick A. Tecce, Esq. ftecce@mcshea-tecce.com McShea/Teece P.C. The Bell Atlantic Tower 28th Floor 1717 Arch Street Philadelphia, PA 19103 Attorneys for CROSS ATLANTIC CAPITAL PARTNERS, INC. By: /s/ Heidi L. Keefe Heidi L. Keefe hkeefe@whitecase.com Mark R. Weinstein mweinstein@whitecase.com Sam O'Rourke sorourke@whitecase.com WHITE & CASE LLP 3000 El Camino Real 5 Palo Alto Square, 9th Floor Palo Alto, CA 94306 Alfred W. Zaher zaher@blankrome.com Dennis P. McCooe mccooe@blankrome.com BLANK ROME LLP 130 N 18th St Philadelphia, PA 19103 Attorneys for FACEBOOK, INC. and THEFACEBOOK, LLC APPROVED and SO ORDERED by the Court: _________________________________ Dated: PALOALTO 86273 v1 (2K) 2 CERTIFICATE OF SERVICE This is to hereby certify that on this 6th day of February, 2008, I caused a true and correct copy of the foregoing documents: STIPULATION TO CONTINUE EXPERT REPORT DEADLINES AND THE DISCOVERY CUTOFF to be served via this Court's Electronic Filing ("ECF") System, upon the following: Frederick A. Tecce, Esq. McShea/Tecce, P.C. The Bell Atlantic Tower 28th Floor 1717 Arch Street Philadelphia, PA 19103 ftecce@mcshea-tecce.com Thomas J. Duffy, Esq. Patrick J. Keenan, Esq. Duffy & Keenan One Liberty Place, 55th Floor 1650 Market Street Philadelphia, PA 19103 pjk@duffykeenan.com Counsel for plaintiff Cross Atlantic Capital Partners, Inc. /s/ Heidi L. Keefe Heidi L. Keefe PALOALTO 86273 v1 (2K) 3

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