h
ddition,
each
side
is
limited to
25
additionalinterrogatories
in
the
unclean
hands
phase
and
25
additional
interrogatories
total
in
lfie
patentjconduct phase.
Thex
are
nolimits
on
requests
for
admission or requests
for
production
b.
DiscovervCut-Off.
All
discovery
in
this
case
shall
be
served
so
as
to
becompleted on or before
the
dates
set
forth bclow in
Exhibit
A.
IJnless
otherwise ordered
by
the
Court
or agreed
by the
parties, the limitations
on
discovery
set
f0rt.h
in
Local Rule 26.1
shall
bestrictly
observed
C
Disclosure
of
Expert Testimony.Unless otlierwise agreed
to
by
the
parties,
theyshall
file
any
supplemental Federal
Rule
of
Civil Procedure
26(a)(2)
disclosures
of
expert testimony relative
to
the
patent and conduct
issues
on
or
before
the
dates set
forth
below
in
Exhibit
A
Unless olherwise agreed
to
by
the
parties,
they
shall
file
any
supplemental FederalRule
of
Civil
Procedure
26(a)(2)
disclosures of expert testimony relative
to
the
unclean
handsissues
on
or
before
sixty
days
before
the
date
of
the
completion
of
discovery relativetothose
issues,
and
file a supplemental disdosure
to
contradict
or
rebut
evidence
on
the
same
subject
matler
identified
by
another
party thirty
days before
the
date
for
the
completion
of
discoverydative
to
the
unclean
hands
issues.
To
the extent
any
objection
to
expert testimony
is
made
pursuant
to
the
principles announced
in
Daubert
v.
Menell
Dow
Pharm.,
Inc.,
509
US.
79
(1993),
it
shall
be
made
by
motion
no
late1
than
the
deadline
for
dispositive
motions
set
forth
herein for
the
patent and conduct phases,
unless
otherwise
ordeled
by
the
Court.
As
to
the
unclean
hands
phase
any
Dnuberi
motion shall be
filed
on
or before July
3
1,2006
dDiscoverv Disuutes. Should counsel
find
they
are
unable
to
resolve
a
discovery dispute, the
party
seehg the
relief
shall
contact
chambers
at
(302)
573-6001
toschedule
a
telephone conference. Not less
than
forty-eight
hours
prior to
the
conference,
the
2
RL-FI-2986519-1
Case 5:05-cv-00334-RMW Document 3105-2 Filed 01/13/2009 Page 3 of 10
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