Public Engines v. Reportsee

Filing 21

Stipulated MOTION for Discovery Plan and Scheduling Order, MOTION for Scheduling Order filed by Plaintiff Public Engines. (Attachments: # 1 Exhibit Proposed Order)(Sullivan, Alan)

Alan L. Sullivan (3152) Todd M. Shaughnessy (6651) Snell & Wilmer L.L.P. 15 West South Temple, Suite 1200 Beneficial Tower Salt Lake City, Utah 84101-1004 Telephone: [phone] Facsimile: [phone] Mark Lambert (Cal. Bar No. 197410) Mark Weinstein (Cal Bar No. 193043) Cooley Godward Kronish, LLP Five Palo Alto Square Palo Alto, California 94306-2109 Telephone: [phone] Attorneys for Plaintiff IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF UTAH, CENTRAL DIVISION PUBLIC ENGINES, INC., a Delaware Corporation, Plaintiff, vs. REPORTSEE, INC., a Delaware Corporation, Defendant.

STIPULATED MOTION FOR ENTRY OF DISCOVERY PLAN AND SCHEDULING ORDER Case No. 2:10-cv-317 Honorable Tena Campbell

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Plaintiff Public Engines, Inc. ("Public Engines") and Defendant ReportSee, Inc. ("ReportSee") stipulate and jointly move for an order modifying the schedule established at the April 14 Status Conference. The parties seek a slight modification to the discovery and filing deadlines to accommodate the schedules of their clients and the rigors of document production. The parties are not requesting that the Court move the June 11, 2010 preliminary injunction hearing date, which is almost three weeks from the date that Plaintiff's reply would be due under the proposed schedule. The parties stipulate and jointly move to set the deadlines as follows: April 30, 2010: May 14, 2010: May 24, 2010: June 11, 2010: Completion of Discovery ReportSee's Opposition to Public Engine's Preliminary Injunction Public Engine's Reply In Support Of Its Preliminary Injunction Motion (Currently due by May 17, 2010.) Preliminary Injunction Hearing

The parties also request leave to take the depositions of the named declarants outside of the discovery schedule. The parties have agreed that ReportSee will take the depositions of Public Engines' declarants on May 4-5, 2010. They have also agreed that Public Engines will take the deposition of ReportSee's declarant on May 18, 2010.

Dated this 27th day of April, 2010

BOWIE & JENSEN, LLC

/s/ Joshua A. Glikin Joshua A. Glikin Attorney for ReportSee, Inc. (Signed with Permission)

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Dated this 27th day of April, 2010

Snell & Wilmer L.L.P.

/s/ Alan L. Sullivan Alan L. Sullivan Todd. M. Shaughnessy Attorneys for Defendant Public Engines, Inc.

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Certificate of Service I certify that on the 27th day of April, 2010, a true and correct copy of the Stipulated Motion for Entry of Discovery Plan and Scheduling Order has been served on the following through ECF: Walter E. Diercks [e-mail] Joshua A. Glikin [e-mail] Jeffrey J. Hunt [e-mail] David C. Reymann [e-mail]

/s/ Alan L. Sullivan

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