Free Stipulation - District Court of California - California

Case 3:07-cv-03177-MMC

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M ANATT , P HELPS & P HILLIPS , LLP
ATTORNEYS AT LAW PALO ALTO

MANATT, PHELPS & PHILLIPS, LLP ROBERT D. BECKER (Bar No. CA 160648) E-mail: [email protected] EUGENE L. HAHM (Bar No. CA 167596) E-mail : [email protected] SHAWN G. HANSEN (Bar No. CA 197033) E-mail: [email protected] 1001 Page Mill Road, Building 2 Palo Alto, CA 94304-1006 Telephone: (650) 812-1300 Facsimile: (650) 213-0260 Attorneys for Defendant and Counterclaimant VISTO CORPORATION UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

RESEARCH IN MOTION LIMITED, Plaintiff, vs. VISTO CORPORATION, Defendant. VISTO CORPORATION, Counterclaimant, vs. RESEARCH IN MOTION LIMITED, and RESEARCH IN MOTION CORPORATION, Counterdefendants.

Case No. C-07- 3177 (MMC) STIPULATION AND [PROPOSED] ORDER MODIFYING COURT DEADLINES UNDER PATENT RULES 4-2, 4-3 AND 4-4

Case 3:07-cv-03177-MMC

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Visto Corporation and Research In Motion Limited and Research In Motion Corporation, through their respective counsel, stipulate as follows: 1. On October 1, 2007, the parties filed a CASE MANAGEMENT AND DOCKET

4 CONTROL ORDER (Docket No. 21) ("Case Management Order"); 5 2. On October 9, 2007, the Court issued an order adopting with certain exceptions the 6 Case Management Order (Docket No. 22); 7 3. The Exchange of Preliminary Claim Constructions under Patent L.R. 4-2 is 8 currently scheduled for January 10, 2008; and 9 4. The filing of the Joint Claim Construction and Prehearing Statement under Patent 10 L.R. 4-3 is currently scheduled for February 11, 2008; 11 5. The date for the completion of Claim Construction Discovery under Patent L.R. 12 4-4 is currently scheduled for March 12, 2008; and 13 6. The Parties currently are in the process of meeting and conferring on the terms to 14 be construed and believe that additional time is necessary to complete the meet and 15 confer process. 16 In order to complete a meaningful meet and confer on the terms to be construed, the 17 parties hereby agree, subject to approval by the Court, to the following modifications to the Case 18 Management Order: 19 1. 20 4-2 shall be extended from January 10, 2008 to January 24, 2008; 21 2. 22 Patent L.R. 4-3 shall be extended from February 11, 2008 to February 25, 2008; 23 3. 24 4-4 shall be extended from March 12, 2008 to March 26, 2008; 25 4. 26 Patent L.R. 4-4 and does not relate to any other phase of this case; and 27 5. 28
M ANATT , P HELPS & P HILLIPS , LLP
ATTORNEYS AT LAW PALO ALTO

The date of the Exchange of Preliminary Claim Constructions under Patent L.R.

The date for filing the Joint Claim Construction and Prehearing Statement under

The date for the completion of Claim Construction Discovery under Patent L.R.

This stipulation is limited to compliance with Patent L.R. 4-2, Patent L.R. 4-3 and

No other deadlines under the Case Management Order are affected by this 2
STIPULATION AND [PROPOSED] ORDER MODIFYING PATENT RULE 4-2, PATENT RULE 4-3, AND PATENT RULE 4-4 SCHEDULE

Case 3:07-cv-03177-MMC

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stipulation.

IT IS SO STIPULATED. DATED: January 9, 2008 MANATT, PHELPS & PHILLIPS, LLP

By: /s/ Eugene L. Hahm Eugene L. Hahm Attorneys for Defendant and Counterclaimant VISTO CORPORATION

.

DATED: January 9, 2008 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
M ANATT , P HELPS & P HILLIPS , LLP
ATTORNEYS AT LAW PALO ALTO

KIRKLAND & ELLIS LLP By: /s/ Philip T. Chen Philip T. Chen Attorneys for Plaintiff and Counterdefendants RESEARCH IN MOTION LIMITED, and RESEARCH IN MOTION CORPORATION

Filer's Attestation: Pursuant to General Order No. 45, Section X(B) regarding signatures, Eugene Hahm hereby attests that concurrence in the filing of this document has been obtained.

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STIPULATION AND [PROPOSED] ORDER MODIFYING PATENT RULE 4-2, PATENT RULE 4-3, AND PATENT RULE 4-4 SCHEDULE

Case 3:07-cv-03177-MMC

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M ANATT , P HELPS & P HILLIPS , LLP
ATTORNEYS AT LAW PALO ALTO

ORDER Good cause appearing, the parties' stipulation is hereby GRANTED. The deadlines for compliance with Patent L.R. 4-2 - 4-4 as set forth in the stipulation are modified as follows:

Exchange of Preliminary Claim Constructions under Patent L.R. 4-2 Joint Claim Construction and Prehearing Statement under Patent L.R. 4-3 Completion of Claim Construction Discovery under Patent L.R. 4-4

January 24, 2008

February 25, 2008

March 26, 2008

PURSUANT TO STIPULATION, IT IS SO ORDERED. DATED this _____ day of January, 2008

_______________________________ HON. MAXINE M. CHESNEY UNITED STATES DISTRICT JUDGE

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