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, ).

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.

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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
[phone] / [phone] Fax

/s/ Daniel R. Castro (with permission)

Daniel R. Castro
CASTRO & BAKER, LLP
7800 Shoal Creek Blvd., Suite 100N
Austin, TX 78757
[phone] / [phone] 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
[phone] / [phone] Fax
Jennifer L. Barry (admitted pro hac vice)
LATHAM & WATKINS LLP
600 West Broadway, Suite 1800
San Diego CA 92101-3375
[phone] / [phone] Fax
Attorneys for Defendant and Counterclaimant
ENTREPRENEUR MEDIA, INC.

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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

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SD\806200.1