Case 3:20-cv-04423-JD Document 94-1 Filed 09/16/21 Page 1 of 3
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`Exhibit A – Plaintiffs’ Proposed Case Schedule
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`Event
`Plaintiffs to file first amended complaint,
`which will identify all copyrighted works
`
`Plaintiffs to identify preliminary list of
`infringements of copyrighted works (alleged
`infringements identified without Content ID)
`Plaintiffs to serve Rule 26 initial disclosures
`for new parties.
`Defendants’ answer or motion to dismiss
`
`Plaintiffs’ opposition to motion to dismiss
`amended complaint, if any
`Defendants’ reply brief in support of motion
`to dismiss, if any.
`Plaintiffs identify final combined list of
`alleged infringements for purposes of this
`case, which infringements are deemed to be
`amended into the operative complaint
`Deadline for substantial completion of
`rolling document productions
`Deadline for motion for class
`certification/opening class cert expert reports
`due
`Opposition to class certification/rebuttal
`class cert expert reports due
`Deadline for deposing Defendants’ class cert
`experts/close of fact discovery for class
`certification only
`Deadline for reply in support of motion for
`class certification
`
`Plaintiffs’ Proposed Date
`5 days after Court’s entry of scheduling order
`which will include identification of copyrighted
`works; preliminary list of infringements to be
`done per dates below, first as discovery based
`on plaintiff’s position at time of disclosure, with
`final list following Defendants’ use of Content
`ID to identify “matches” for copyrighted works
`with such final list to be deemed incorporated
`into the Complaint at that time.
`14 days after Court’s entry of scheduling order
`
`30 days after filing of amended complaint
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`21 days after filing of amended complaint
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`28 days after motion to dismiss, if any
`
`14 days after deadline for Plaintiffs’ opposition
`to the motion to dismiss
`The later of January 21, 2022 or 60 days after
`Defendants disclose all Content ID matches for
`the copyrighted works contained in the
`amended complaint
`March 4, 2022
`
`July 21, 2022
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`August 25, 2022
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`September 22, 2022
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`September 29, 2022
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`Case 3:20-cv-04423-JD Document 94-1 Filed 09/16/21 Page 2 of 3
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`Event
`Hearing on motion for class certification
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`Close of fact discovery
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`Disclosure of proposed expert or other
`opinion witnesses
`Opening merits expert reports due
`Rebuttal merits expert reports due
`
`Close of merits expert discovery
`
`Deadline to move for summary judgment
`
`Opposition to motions for summary
`judgment
`Reply in support of motions for summary
`judgment
`Hearing on motions for summary judgment
`
`Serving and filing briefs on all significant
`disputed issues of law, including procedural
`and evidentiary issues (motions in limine,
`Daubert motions)
`Counsel to meet and confer to prepare joint
`final pretrial conference statement and
`proposed order and coordinated submission
`of trial exhibits and other material
`Filing joint final pretrial conference statement
`and proposed order, serving and filing
`requested
`voir
`dire
`questions,
`jury
`instructions, and forms of verdict
`Final pretrial conference
`
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`Plaintiffs’ Proposed Date
`October 13, 2022 or first Thursday at least 14
`days after previous event (or per Court’s
`availability)
`Later of January 9, 2023 or 60 days following
`class certification decision
`Later of January 16, 2023 or 7 days following
`previous event
`Same as previous event
`Later of February 20, 2023 or 35 days
`following previous event
`Later of March 20, 2023 or 28 days following
`previous event
`Later of April 10, 2023 or 21 days following
`previous event
`Later of May 8, 2023 or 28 days following
`previous event
`Later of May 30, 2023 or 21 days following
`previous event
`Later of June 15, 2023 or first Thursday at least
`14 days after previous event (or per Court’s
`availability)
`Later of August 14, 2023 or 30 days following
`decision on motion(s) for summary judgment
`
`Later of August 21, 2023 or 7 days following
`previous event
`
`Later of September 5, 2023 or 14 days
`following previous event
`
`Later of September 14, 2023 or first Thursday
`at least 7 days following previous event (or per
`Court’s availability)
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`Case 3:20-cv-04423-JD Document 94-1 Filed 09/16/21 Page 3 of 3
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`Event
`Lodging exhibits and other trial material,
`including copies of all exhibits to be offered
`and all schedules, summaries, diagrams and
`charts to be used at the trial other than for
`impeachment or rebuttal. Each proposed
`exhibit must be premarked for identification.
`Upon request, a party must make the original
`or the underlying documents of any exhibit
`available for inspection and copying
`Serving and filing statements designating
`excerpts from depositions (specifying the
`witness and page and line references), from
`interrogatory answers and from responses to
`requests for admission to be offered at the trial
`other than for impeachment or rebuttal
`Trial
`
`Plaintiffs’ Proposed Date
`Later of September 21, 2023 or 7 days
`following previous event
`
`Later of September 21, 2023 or 7 days
`following final pretrial conference
`
`Later of October 12, 2023 or 21 days following
`final pretrial conference
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