Rockstar Consortium US LP et al v. Google Inc

Filing 209

Unopposed MOTION for Issuance of Letters Rogatory to Edouard Gueyffier by Google Inc. (Attachments: # 1 Exhibit A, # 2 Affidavit Declaration of Michelle Ernst, # 3 Exhibit 1, # 4 Exhibit 2, # 5 Exhibit 3, # 6 Exhibit 4, # 7 Exhibit 5, # 8 Exhibit 6, # 9 Exhibit 7, # 10 Exhibit 8, # 11 Exhibit 9, # 12 Exhibit 10, # 13 Exhibit 11, # 14 Text of Proposed Order)(Perlson, David)

Download PDF
EXHIBIT 11 Case 2:13-cv-00893-JRG-RSP Document 68 Filed 05/13/14 Page 1 of 5 PageID #: 878 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION ROCKSTAR CONSORTIUM US LP AND NETSTAR TECHNOLOGIES LLC Plaintiffs, Case No. 2:13-cv-00893-JRG-RSP JURY TRIAL DEMANDED v. GOOGLE INC. Defendant. DOCKET CONTROL ORDER It is hereby ORDERED that th e following schedule of deadline s is in ef fect until further order of this Court: June 8, 2015 *Jury Selection – 9:00 a.m. in Marshall, Texas April 27, 2015 *Pretrial Conference – 9:00 a.m. in Marshall, Texas before Judge Roy Payne April 22, 2015 *Notify Court of Agreements Reached During Meet and Confer The parties are ordered to m eet and confer on any outstanding objections or motions in limine. The parties shall advise the Court of any agreements reach ed no later than 1:00 p.m. three (3) busines s days before the pretrial conference. April 20, 2015 *File Joint Pretrial Order, Joint Proposed Jury Instructions, Joint Proposed Verdict Form, and Responses to Motions in Limine April 13, 2015 *File Notice of Request for Daily Transcript or Real Time Reporting. If a daily tr anscript or real tim e reporting of court proceedings is requested for trial, the party or parties making said request shall file a notice with the Court an d e-mail the Court Reporter, Shelly Holmes, at shelly_holmes@txed.uscourts.gov. 01980.51575/5896345.2 Case 2:13-cv-00893-JRG-RSP Document 68 Filed 05/13/14 Page 2 of 5 PageID #: 879 April 6, 2015 File Motions in Limine The parties shall lim it their m otions in limine to issue s that if improperly introduced at trial would be so prejudicial that the Court could not alleviate the prejudice by giving appropriate instructions to the jury. April 6, 2015 Serve Objections to Rebuttal Pretrial Disclosures March 30, 2015 Serve Objections to Pretrial Disclosures; and Serve Rebuttal Pretrial Disclosures March 16, 2015 Serve Pretrial Disclo sures (Witness List, Deposition Des ignations, and Exhibit List) by the Party with the Burden of Proof March 13, 2015 *File Dispositive Motions or Motio ns to Strike Expert Testim ony (including Daubert Motions) No dispositive m otion or m otion to strike expert testim ony (including a Daubert motion) m ay be filed af ter this date without leave of the Court. March 9, 2015 Deadline to Complete Expert Discovery February 16, 2015 Serve Disclosures for Rebuttal Expert Witnesses January 19, 2015 Serve Disclosures for Expert Witnesses by the Party with the Burden of Proof January 12, 2015 Deadline to File Motions to Compel Discovery January 7, 2015 Deadline to Complete Fact Discovery December 22, 2014 *Deadline to File Letter Briefs Regarding Dispositive Motions November 25, 2014 Deadline to Complete Mediation The parties are responsible for en suring that a m ediation report is filed no later than 5 days after the conclusion of mediation. See L.R. App. H. November 18, 2014 Comply with P.R. 3-7 (Opinion of Counsel Defenses) October 28, 2014 *Claim Construction Hearing – 9:00 a.m. in Marshall, Texas before Judge Roy Payne. October 14, 2014 *Comply with P.R. 4-5(d) (Joint Claim Construction Chart) 01980.51575/5896345.2 -2- Case 2:13-cv-00893-JRG-RSP Document 68 Filed 05/13/14 Page 3 of 5 PageID #: 880 October 7, 2014 *Comply with P.R. 4-5(c) (Reply Claim Construction Brief) September 30, 2014 Comply with P.R. 4-5(b) (Responsive Claim Construction Brief) September 26, 2014 Deadline to Exchange Privilege Logs September 16, 2014 Comply with P.R. 4-5( a) (Opening Claim Construction Brief) and Submit Technical Tutorials (if any) September 16, 2014 Deadline to Substantially Complete Document Production Counsel are expected to m ake good faith efforts to produce all required documents as soon as they are available and not wait until the substantial completion deadline. September 2, 2014 Comply with P.R. 4-4 (D eadline to Com plete Claim Construction Discovery) August 26, 2014 File Response to Amended Pleadings August 12, 2014 *File Amended Pleadings It is not necessary to seek leave of Court to amend pleadings prior to this deadline unless the amendment seeks to assert additional patents. August 5, 2014 Comply with P.R. 4-3 (Joint Claim Construction Statement) July 15, 2014 Comply with P.R. 4-2 (Exchange Preliminary Claim Constructions) June 24, 2014 Comply with P.R. 4-1 (Exchange Proposed Claim Terms) May 19, 2014 Comply with P.R. 3-3 & 3-4 (Invalidity Contentions) April 28, 2014 *File Proposed Protective Or der and Comply with Paragraphs 1 & 3 of the Discovery Order (Initial and Additional Disclosures) April 21, 2014 *File Proposed Docket Cont rol Order, Proposed Discovery Order, and Notice of Mediator The Proposed Docket Control Or der and the Proposed Discovery Order shall be f iled as separate motions with the caption ind icating whether or not the proposed order is opposed in any part. April 14, 2014 Join Additional Parties March 24, 2014 Comply with P.R. 3-1 & 3-2 (Infringement Contentions) 01980.51575/5896345.2 -3- Case 2:13-cv-00893-JRG-RSP Document 68 Filed 05/13/14 Page 4 of 5 PageID #: 881 (*) indicates a deadline that cannot be changed without showing good cause. Good cause is not shown merely by indicating that the parties agree that the deadline should be changed. ADDITIONAL REQUIREMENTS Notice of Mediator: The parties are to jointly file a notice that identifies the agreed upon mediator or indicates that no agreem ent was reached. If the parties do n ot reach an agreem ent, the Court will appoint a mediator. The parties should not file a list of mediators to be considered by the Court. Summary Judgment Motions : Prior to filing any su mmary judgment m otion, the parties must submit letter briefs seeking perm ission to file the m otion. The opening letter brief in each of those matters shall be no longer than five (5) pages and shall be filed with the Court no later than th e deadline for filing letter briefs. Answering letter briefs in each of those m atters shall be no longer than five (5) pages and filed with the Court no later than fourteen (14) days thereafter. Reply briefs in each of those m atters shall be no longer than three (3) pages and filed with the Court no la ter than five (5) days ther eafter. The Court m ay decide the question on the submissions or hold a hearing or telephone conf erence to hear argum ents and t o determine whether the filing of any motion will be permitted. Letter briefs shall be filed without exhibits. Any requests to submit letter briefs after the deadlines outlined above must show good cause. Indefiniteness: In lieu of early m otions for summary judgment, the parties are directed to include any arguments related to the issue of indefiniteness in their Markman briefing, subject to the local rules’ normal page limits. Motions for Continuance : The following excuses will not warrant a continuance nor justify a failure to comply with the discovery deadline: (a) The fact that there are motions for summary judgment or motions to dismiss pending; (b) The fact that one or more of the attorneys is set for trial in another court on the same day, unless the other setting was m ade prior to the date of this order or was made as a special provision for the parties in the other case; (c) The failure to complete discovery prior to trial, unless the parties can demonstrate that it was impossible to complete discovery despite their good faith effort to do so. 01980.51575/5896345.2 -4- Case 2:13-cv-00893-JRG-RSP Document 68 Filed 05/13/14 Page 5 of 5 PageID #: 882 Amendments to the Docket Control Order (“DCO”): Any motion to alter any date on the DCO shall take the form of motion to amend the DCO. The motion to amend the DCO shall include a proposed order that lists all of the rem aining dates in one column (as above) and the proposed changes to each date in an additional ad jacent column (if there is no change for a date the proposed date column should rem ain blank or indicate that it is unchanged). In other words, the DCO in the proposed order should be com plete such that one can clearly see all the remaining deadlines and the changes, if any, to those dead lines, rather than needing to also refer to an earlier version of the DCO. IT IS SO ORDERED. of January, 2012. SIGNED this 3rd day SIGNED this 12th day of May, 2014. ____________________________________ ROY S. PAYNE UNITED STATES MAGISTRATE JUDGE

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?