Case Management Report in Patent Cases (PDF); Defendant Tags (Use Yellow Paper) (PDF); Government Tags (Use Blue Paper) (PDF); Joint Tags (Use Green Paper) (PDF); Plaintiff Tags (Use Blue Paper) (PDF)

=== Case Management Report in Patent Cases (PDF) ===

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA Choose division Case No. Enter case number Enter name(s), Plaintiffs, v. Enter name(s), Defendants. Case Management Report in Patent Cases The parties have agreed on the following dates and discovery plan pursuant to Fed.R.Civ.P. 26(f) and Local Rule 3.02(a): DEADLINE OR EVENT (with Court recommended time frame) AGREED DATE Mandatory Initial Disclosures (pursuant to Fed.R.Civ.P. 26(a)(1) as amended effective December 1, 2000) [no later than date of Preliminary Pretrial Conference] Certificate of Interested Persons and Corporate Disclosure Statement [Immediately] Motions to Add Parties or Amend Pleadings [3 months after CMR meeting] Disclosure of Infringement Contentions [1 month after CMR meeting] Disclosure of Non-Infringement and Invalidity Contentions [ within 1 month of above] Initial Identification of Disputed Claim Terms [within 1 month of above] 1 DEADLINE OR EVENT (with Court recommended time frame) AGREED DATE Proposed Claim Term Constructions [within 1 month of above] Joint Claim Construction Statement [within 2 weeks of above] Technology Tutorial Conference [within 2 – 4 weeks of above] (if requested, insert date; otherwise, leave blank) Plaintiff’s Claim Construction Brief [within 1 month of above] Defendant’s Response Brief [within 1 month of above] Joint Pre-Hearing Statement [within 1 week of above] Claim Construction Hearing [within 3 weeks of above] Disclosure of Intent to Rely on Advice of Counsel as a Defense; Amendment of Infringement, Non-Infringement and Invalidity Contentions; and Disclosure of Expert Reports on Issues Where the Party Bears the Burden of Proof [no sooner than 3 months and no later than 5 months of above] Disclosure of Rebuttal Expert Reports [within 1 month of above] Fact Discovery Deadline [within 2 months of Amendments] Expert Discovery Deadline [within 1 month of above] Deadline for moving for class certification; if applicable. See Fed R. Civ. P. 23 (c) Dispositive Motions [within 2 months of above and at least 4 – 5 months prior to trial] 2 DEADLINE OR EVENT (with Court recommended time frame) AGREED DATE Parties’ Deadline to Meet and Confer In Person to Prepare Joint Final Pretrial Statement [10 days prior to deadline for the final pretrial statement] Parties’ Deadline for Filing Joint Final Pretrial Statement (Including Voir Dire Questions, a Single Set of Jointly-Proposed Jury Instructions and Verdict Form (also email to [email protected]), Witness Lists, Exhibit Lists with Objections on Approved Form); Trial Briefs Parties’ Deadline for Filing All Other Motions Including Motions In Limine [All requests to limit evidence shall be included in a single motion not to exceed 25 pages without leave of Court. Responses are limited to 20 pages without leave of Court.] Trial Term Begins [the goal is trial within 2 years; trial term must not be less than 4 months after dispositive motions deadline (unless filing of such is waived.] Estimated Length of Trial [trial days] Jury / Non-Jury Mediation Deadline: Mediator : Address Telephone [Absent arbitration, mediation is mandatory; either 2 -3 months after CMR meeting or just after discovery deadline] All Parties Consent to Proceed Before Magistrate Judge Yes No Likely to Agree in Future ___ 3 I. Meeting of Parties in Person Lead counsel must meet in compliance with Local Rule 3.02 (a)(1). Pursuant to Local Rule 3.02(a)(1), a meeting was held on (date) at (time) and was attended by: Name Counsel for (if applicable) II. Pre-Discovery Initial Disclosures of Core Information Fed. R. Civ. P. 26(a)(1)(A)–(D) Disclosures The parties have exchanged agree to exchange (check one) information described in Fed. R. Civ. P. 26(a)(1)(A)–(D) by (date). Below is a description of information disclosed or scheduled for disclosure: III. Electronic Discovery The Court will enter a separate Order regarding electronic discovery. The parties may move to modify the Court’s standard Order by separate motion within two (2) weeks of its issuance. 4 IV. Agreed Discovery Plan for Plaintiffs and Defendants A. Certificate of Interested Persons and Corporate Disclosure Statement This Court has previously ordered each party, governmental party, intervenor, non- party movant, and Rule 69 garnishee to file and serve a Certificate of Interested Persons and Corporate Disclosure Statement using a mandatory form. No party may seek discovery from any source before filing and serving a Certificate of Interested Persons and Corporate Disclosure Statement. A motion, memorandum, response, or other paper “including emergency motion” is subject to being denied or stricken unless the filing party has previously filed and served its Certificate of Interested Persons and Corporate Disclosure Statement. Any party who has not already filed and served the required certificate is required to do so immediately. Every party that has appeared in this action to date has filed and served a Certificate of Interested Persons and Corporate Disclosure Statement, which remains current: Yes No Certificate will be filed by (party) on or before date). B. Discovery Not Filed The parties shall not file discovery materials with the Clerk except to support a motion. The parties further agree as follows: C. Limits on Discovery Absent leave of Court, the parties may take no more than ten depositions per side 5 (not per party). Fed.R.Civ.P. 30(a)(2)(A); Fed.R.Civ.P. 31(a)(2)(A). Absent leave of Court, the parties may serve no more than twenty-five interrogatories, including sub- parts. Fed.R.Civ.P. 33(a). Absent leave of Court or stipulation of the parties each deposition is limited to one day of seven hours. Fed.R.Civ.P. 30(d)(2). The parties may agree by stipulation on other limits on discovery. The Court will consider the parties’ agreed dates, deadlines, and other limits in entering the scheduling order. Fed.R.Civ.P. 29. In addition to the deadlines in the above table, the parties have agreed to further limit discovery as follows: 1. Depositions 2. Interrogatories 3. Document Requests 4. Requests to Admit 5. Supplementation of Discovery D. Discovery Deadline Each party shall timely serve discovery requests so that the rules allow for a response prior to the discovery deadline. The Court may deny as untimely all motions to compel filed after the discovery deadline. In addition, the parties agree as follows: 6 E. Disclosure of Expert Testimony On or before the dates set forth in the above table for the disclosure of expert reports, the parties agree to fully comply with Fed.R.Civ.P. 26(a)(2) and 26(e). Expert testimony on direct examination at trial will be limited to the opinions, basis, reasons, data, and other information disclosed in the written expert report disclosed pursuant to this order. Failure to disclose such information may result in the exclusion of all or part of the testimony of the expert witness. The parties agree on the following additional matters pertaining to the disclosure of expert testimony: VI. Mediation and Alternative Dispute Resolution. A. Mediation Absent arbitration or a Court order to the contrary, the parties in every case will participate in Court-annexed mediation as detailed in Chapter Four of the Court’s Local Rules. The parties have agreed on a mediator from the Court’s approved list of mediators as set forth in the table above and have agreed to the date stated in the table above as the last date for mediation. The list of mediators is available from the Clerk and is posted on the Court’s web site at http://www.flmd.uscourts.gov. 7 B. Other Alternative Dispute Resolution The parties intend to pursue the following other methods of alternative dispute resolution: Date: Signature of Counsel (with information required by Fed. R. Civ. P. 11(a and Signature of Unrepresented Parties. 8

=== Defendant Tags (Use Yellow Paper) (PDF) ===

U.S. District Court Middle District of Florida U.S. District Court Middle District of Florida U.S. District Court Middle District of Florida DEFENDANT’S EXHIBIT DEFENDANT’S EXHIBIT DEFENDANT’S EXHIBIT Exhibit Number: Exhibit Number: Exhibit Number: Case Number: Case Number: Case Number: v. v. Date Identified: Date Admitted: Date Identified: Date Admitted: v. Date Identified: Date Admitted: U.S. District Court Middle District of Florida U.S. District Court Middle District of Florida U.S. District Court Middle District of Florida DEFENDANT’S EXHIBIT DEFENDANT’S EXHIBIT DEFENDANT’S EXHIBIT Exhibit Number: Exhibit Number: Exhibit Number: Case Number: v. Date Identified: Date Admitted: Case Number: v. Date Identified: Date Admitted: Case Number: v. Date Identified: Date Admitted:

=== Government Tags (Use Blue Paper) (PDF) ===

U.S. District Court Middle District of Florida U.S. District Court Middle District of Florida U.S. District Court Middle District of Florida GOVERNMENT’S EXHIBIT GOVERNMENT’S EXHIBIT GOVERNMENT’S EXHIBIT Exhibit Number: Exhibit Number: Exhibit Number: Case Number: v. Date Identified: Date Admitted: Case Number: Case Number: v. v. Date Identified: Date Admitted: Date Identified: Date Admitted: U.S. District Court Middle District of Florida U.S. District Court Middle District of Florida U.S. District Court Middle District of Florida GOVERNMENT’S EXHIBIT GOVERNMENT’S EXHIBIT GOVERNMENT’S EXHIBIT Exhibit Number: Exhibit Number: Exhibit Number: Case Number: Case Number: Case Number: v. Date Identified: Date Admitted: v. Date Identified: Date Admitted: v. Date Identified: Date Admitted:

=== Joint Tags (Use Green Paper) (PDF) ===

U.S. District Court Middle District of Florida U.S. District Court Middle District of Florida U.S. District Court Middle District of Florida JOINT EXHIBIT JOINT EXHIBIT JOINT EXHIBIT Exhibit Number: Exhibit Number: Exhibit Number: Case Number: v. Date Identified: Date Admitted: Case Number: v. Date Identified: Date Admitted: Case Number: v. Date Identified: Date Admitted: U.S. District Court Middle District of Florida U.S. District Court Middle District of Florida U.S. District Court Middle District of Florida JOINT EXHIBIT JOINT EXHIBIT JOINT EXHIBIT Exhibit Number: Exhibit Number: Exhibit Number: Case Number: Case Number: Case Number: v. v. Date Identified: Date Admitted: Date Identified: Date Admitted: v. Date Identified: Date Admitted:

=== Plaintiff Tags (Use Blue Paper) (PDF) ===

U.S. District Court Middle District of Florida U.S. District Court Middle District of Florida U.S. District Court Middle District of Florida PLAINTIFF’S EXHIBIT PLAINTIFF’S EXHIBIT PLAINTIFF’S EXHIBIT Exhibit Number: Exhibit Number: Exhibit Number: Case Number: v. Date Identified: Date Admitted: Case Number: Case Number: v. Date Identified: Date Admitted: v. Date Identified: Date Admitted: U.S. District Court Middle District of Florida U.S. District Court Middle District of Florida U.S. District Court Middle District of Florida PLAINTIFF’S EXHIBIT PLAINTIFF’S EXHIBIT PLAINTIFF’S EXHIBIT Exhibit Number: Exhibit Number: Exhibit Number: Case Number: Case Number: Case Number: v. v. v. Date Identified: Date Admitted: Date Identified: Date Admitted: Date Identified: Date Admitted: