WI-LAN Inc. v. Alcatel-Lucent USA Inc. et al

Filing 285

RESPONSE in Opposition re 277 MOTION for Leave to File Two Letter Briefs Requesting Permission to File Certain Motions filed by WI-LAN Inc.. (Attachments: # 1 Affidavit Declaration of Syed Fareed, # 2 Exhibit A - Docket Control Order, # 3 Text of Proposed Order)(Fareed, Syed)

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EXHIBIT A Current Date November 30, 2012 Proposed New Date December 21, 2012 Event Deadline to complete expert discovery Deadline to file letter briefs regarding Dispositive Motions and any other motions that may require a hearing (including Daubert motions) December 7, 2012 January 18, 2013 Dispositive Motions due from all parties and any other motions that may require a hearing (including Daubert motions) due January 18, 2013 February 8, 2013 Oppositions to Dispositive Motions (including Daubert motions) due. None February 22, 2013 Reply to Dispositive Motions (including Daubert motions) due. January 25, 2013 February 28, 2013 Joint Pretrial Order, Joint Proposed Jury Instructions with citation to authority and Form of the Verdict for jury trials dues. Proposed Findings of Fact and Conclusions of Law with citation to authority for issues tried to the bench. Notice of Request for Daily Transcript or Real time Reporting of Court Proceedings due. If a daily transcript or real time reporting of court proceedings is requested for trial or hearings, the party or parties making said request shall file a notice with the Court and email the Court Reporter, Shea Sloan, at shea_sloan@txed.uscourts.gov. February 13, 2013 February 28, 2013 Pretrial Disclosures due. Video and Stenographic Deposition Designation due. Each party who proposes to offer deposition testimony shall file a disclosure identifying the line and page numbers to be offered. February 25, 2013 March 8, 2013 Rebuttal Designations and Objections to Deposition Testimony due. Cross examination line and page numbers to be included. In video depositions, each party is responsible for preparation of the final edited video in accordance with their parties’ designations and the Court’s rulings on objections. March 1, 2013 March 15, 2013 Objections to Rebuttal Deposition Testimony due. SMRH:407452973.1 -1- Current Date March 11, 2013 Proposed New Date March 15, 2013 Event Pretrial Objections due Motions in Limine due. The parties are directed to confer and advise the Court on or before 3:00 o’clock p.m. the day before the pre-trial conference which paragraphs are agreed to and those that need to be addressed at the pre-trial conference. March 15, 2013 March 18, 2013 Responses to Motions in Limine due. March 18, 2013 Unchanged Parties to file estimates of the amount of time they request at jury selection and trial for (1) voir dire, (2) opening statements, (3) direct and cross examinations, and (4) closing arguments. March 21, 2013 Unchanged 9:00 a.m. PRETRIAL CONFERENCE at the United States District Court, 211 W. Ferguson, 3rd Floor, Courtroom of Judge Leonard Davis, Tyler, Texas. Court designated date – not flexible without good cause - Motion Required All pending motions will be heard. Lead trial counsel must attend the pretrial conference. April 1, 2013 Unchanged 9:00 a.m. JURY SELECTION at the United States District Court, 211 W. Ferguson, 3rd Floor, Courtroom of Judge Leonard Davis, Tyler, Texas. Unchanged EXHIBITS & EXHIBIT LISTS: Each party shall provide the Court with one set of exhibits and three copies of the exhibit list. The Court’s preferred format for Exhibit Lists is available on the Court’s website at www.txed.uscourts.gov under “Orders & Forms.” Court designated date – not flexible without good cause - Motion Required April 8, 2013 The parties are further requested to have all exhibits labeled with the following information on each label: Designation of Plaintiff’s or Defendant’s Exhibit Number and Case Number. At the conclusion of the evidentiary phase of trial, each party shall be responsible for pulling those exhibits admitted at trial to be submitted to the jury. SMRH:407452973.1 -2- Current Date Proposed New Date Event In addition, each party shall submit to the Court a Final Exhibit List of all of their exhibits admitted during trial. At the conclusion of trial, all boxes of exhibits shall be returned to the respective parties and the parties are instructed to remove these exhibits from the courtroom. Within two business days of the conclusion of trial, each party shall submit to the Court the following: (1) A disk or disks containing all admitted trial exhibits in PDF format. If tangible exhibits were admitted, such exhibits shall be substituted with a photograph to be converted to a PDF file and shall be included in the Court’s disk of admitted exhibits. If the Court ordered any exhibits sealed during trial, the Sealed Exhibits shall be copied on a separate disk. (2) A disk or disks containing the transcripts of Video Depositions played during trial, along with a copy of the actual video deposition. After verification of exhibit lists by the Clerk, the lists shall be filed by the Clerk, and the disk or disks containing the exhibits in PDF format shall be stored in the Clerk’s Office, Tyler Division. April 8, 2013 Court designated date – not flexible without good cause - Motion Required SMRH:407452973.1 Unchanged 9:00 a.m. JURY TRIAL as reached at the United States District Court, 211 W. Ferguson, 3rd Floor, Courtroom of Judge Leonard Davis, Tyler, Texas. (per 7/6 DCO) -3-

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