`
`Event
`Deadline to file amended
`pleadings
`
`Defendants’ September 2021 Schedule Proposal
`
`Date
`Plaintiff Schneider and Proposed Plaintiffs AST and
`Uniglobe shall file the amended complaint within 5 days
`of the Court’s order entering this schedule, which shall
`include a final identification of all works in suit and
`preliminary identification by URL of all allegedly
`infringing videos known to Plaintiffs as of this date
`
`10 days after filing of amended complaint
`
`Deadline for new plaintiffs
`to serve Rule 26 initial
`disclosures
`
`Deadline for defendants’
`response to amended
`complaint
`
`Deadline for Plaintiffs to
`serve final identification by
`URL of any additional
`videos that they allege
`infringe the pleaded works in
`suit in this action, which
`infringements are deemed to
`be amended into the
`operative complaint
`
`Deadline for Plaintiffs to file
`motion for class certification
`Deadline for Defendants to
`file opposition to Plaintiffs’
`motion for class certification
`Deadline for Plaintiffs to file
`reply in support of motion
`for class certification
`Hearing on Plaintiffs’
`motion for class certification
`Close of fact discovery
`
`Disclosure of proposed
`expert or other opinion
`witnesses
`Opening expert reports due
`Rebuttal expert reports due
`Close of expert discovery
`Deadline to move for
`summary judgment
`Deadline to file opposition to
`motion for summary
`judgment
`
`Normal.dotm
`
`28 days after filing of amended complaint
`
`
`January 21, 2022
`
`January 27, 2022
`
`March 10, 2022
`
`March 31, 2022
`
`TBD based on Court’s availability
`
`July 22, 2022
`
`July 29, 2022
`
`August 12, 2022
`September 16, 2022
`October 14, 2022
`November 11, 2022
`
`December 16, 2022
`
`
`
`Case 3:20-cv-04423-JD Document 94-2 Filed 09/16/21 Page 2 of 3
`
`Deadline to file reply in
`support of motion for
`summary judgment
`Hearing on motion(s) 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
`
`January 19, 2023
`
`TBD based on Court’s availability
`
`April 10, 2023
`
`April 17, 2023
`
`May 1, 2023
`
`Serving and filing requested
`voir dire questions, jury
`instructions, and forms of
`verdict
`Final pretrial conference
`
`
`May 1, 2023
`
`May 8, 2023
`
`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
`
`Normal.dotm
`
`May 15, 2023
`
`May 15, 2023
`
`-2-
`
`
`
`Case 3:20-cv-04423-JD Document 94-2 Filed 09/16/21 Page 3 of 3
`
`references), from
`interrogatory answers and
`from responses to requests
`for admission to be offered
`at the trial other than for
`impeachment or rebuttal
`Trial
`
`
`
`
`May 29, 2023
`
`Normal.dotm
`
`-3-
`
`