Castro v. Entrepreneur Media, Inc.

Filing 75

STATUS REPORT Joint Discovery Plan by Entrepreneur Media, Inc. and Daniel R. Castro. (Barry, Jennifer) Modified on 10/5/2011 to add filer (dm, ).

Download PDF
UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION DANIEL R. CASTRO, Plaintiff, v. ENTREPRENEUR MEDIA, INC., Defendant. ENTREPRENEUR MEDIA, INC., Counterclaimant, v. DANIEL R. CASTRO, Counterdefendant. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Cause No. 1-10-CV-000695-LY-AWA Hon. Lee Yeakel JOINT DISCOVERY PLAN The parties conducted the Rule 26(f) discovery conference on September 19, 2011, and have agreed as follows: 1. The parties will exchange initial disclosures on Friday, October 14, 2011. 2. The parties are permitted to conduct fact discovery through Friday, December 9, 2011. Discovery requests should be served sufficiently in advance of this deadline so that responses are due on or before this date. 3. The parties will exchange expert disclosures on or before Tuesday, January 31, 2012. Rebuttal disclosures (if any) will be served on or before Wednesday, February 15, 2012. 4. The parties are permitted to conduct expert discovery through Friday, March 9, 5. Subject to Court approval, the deadline to file dispositive motions will be 2012. extended from Monday, January 30, 2012 to Friday, March 23, 2012. SD\806200.1 6. The parties will negotiate and file a stipulated protective order governing confidential materials on or before Friday, October 14, 2011. 7. Discovery of electronically stored information (“ESI”) will be conducted according to the protocols agreed upon by the parties. 8. Service of documents in this action can be sent via email. Service via email will be equivalent to personal service under FRCP 5(b)(2)(A) for purposes of calculating deadlines under FRCP 6(d). Documents e-filed with the Court via ECF do not need to be served, via email, or otherwise, per Local Rule CV-5(b)(1). Dated: October 4, 2011 By: By: /s/ Jennifer L. Barry William G. Barber Texas Bar No. 01713050 PIRKEY BARBER LLP 600 Congress Avenue, Suite 2120 Austin, TX 78701 (512) 322-5200 / (512) 322-5201 Fax /s/ Daniel R. Castro (with permission) Daniel R. Castro CASTRO & BAKER, LLP 7800 Shoal Creek Blvd., Suite 100N Austin, TX 78757 (512) 732-0111 / (512) 732-0115 Fax Plaintiff and Counterdefendant Perry J. Viscounty (admitted pro hac vice) LATHAM & WATKINS LLP 650 Town Center Drive, 20th Floor Costa Mesa, CA 92626-1925 (714) 540-1235 / (714) 755-8290 Fax Jennifer L. Barry (admitted pro hac vice) LATHAM & WATKINS LLP 600 West Broadway, Suite 1800 San Diego CA 92101-3375 (619) 238-3024 / (619) 696-7419 Fax Attorneys for Defendant and Counterclaimant ENTREPRENEUR MEDIA, INC. 2 SD\806200.1 CERTIFICATE OF SERVICE I hereby certify the on October 4, 2011, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to all parties. /s/ Jennifer L. Barry Jennifer L. Barry 3 SD\806200.1

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?