United States District Court, D. Nevada
BUETHER JOE & CARPENTER, LLC, Christopher M. Joe, Kenneth
P. Kula, Brian A. Carpenter, Daniel T. Foley, Esq., FOLEY
& OAKES, PC Attorneys for Defendant Mode Tech (Beijing)
McDonald Carano LLP, Kristen T. Gallagher, Amanda C. Yen,
David P. Shouvlin, PORTER WRIGHT MORRIS & ARTHUR LLP
Attorneys for Konecranes Global Corporation.
AMENDED DISCOVERY PLAN AND SCHEDULING ORDER SPECIAL
SCHEDULING REVIEW REQUESTED FOR A PATENT CASE
J. KOPPE, UNITED STATES MAGISTRATE JUDGE.
to the Court's Orders dated April 5, 2019 and April 8,
2019, as well as Rule 26(f) of the Federal Rules of Civil
Procedure, Local Rule 26-1, and the Local Patent Rules,
Plaintiff Konecranes Global Corporation
("Konecranes") and Defendant Mode Tech (Beijing)
Co., Ltd. ("Mode Tech") submit the below-provided
Amended Discovery Plan and Scheduling Order. The parties have
amended the Discovery Plan and Scheduling Order to reflect
that this plan is agreed upon and not a "tentative"
in accordance with Local Rule 26-1(a), which states, in part,
"Plans requesting special scheduling review must
include, in addition to the information required by
Fed.R.Civ.P. 26(f) and LR 26-1(b), a statement of the reasons
why longer or different time periods should apply to the
case," LR 26-1(a), the parties provide the following
statement: The parties request this limited additional time
in light of Mode Tech's Motion to Dismiss for Failure to
Properly Effectuate Service of Process, ECF No. 30. The
motion is fully briefed and before the Court. In addition,
Plaintiff Konecranes is based in Hyvinkaa, Finland, and
Defendant Mode Tech is based in Beijing, China; facilitating
the claim construction and discovery processes
internationally will likely require additional time.
INFORMATION PROVIDED PURSUANT TO FED. R. CIV. P. 26(f) and LR
parties propose to serve initial disclosure statements
pursuant to Fed.R.Civ.P. 26(a)(1) no later than July 1, 2019.
Subjects, Timing, And Phasing Of Discovery:
Issues Regarding Disclosure Of Electronically Stored
parties will prepare a detailed stipulation governing the
discovery of electronically stored information, to be filed
with the Court.
Issues About Claims Of Privilege/Protection Of Trial
parties intend to adopt the provisions set forth in
Fed.R.Evid. 502(d) and (e) governing the inadvertent
disclosure of privileged or protected documents. The parties
shall submit the proposed ...