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`IN THE UNITED STATES COURT OF FEDERAL CLAIMS
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`E-NUMERATE SOLUTIONS, INC. and
`E-NUMERATE, LLC,
`Plaintiffs,
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`v.
`THE UNITED STATES OF AMERICA,
`Defendant.
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`C.A. No. 19-859-RTH
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`PLAINTIFFS’ UNOPPOSED MOTION TO AMEND THE
`SCHEDULING ORDER
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`Plaintiffs e-Numerate Solutions, Inc., and e-Numerate, LLC (collectively “e-Numerate” or
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`“Plaintiffs”) hereby moves this Court to amend the current Scheduling Order (D.I. 64) in this
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`matter in light of conflicts with Plaintiffs’ counsel’s trial schedule and the availability of
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`Plaintiffs’ client representatives to review Plaintiffs’ opening claim construction brief. The
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`parties met and conferred, and the Government does not oppose this motion. In support thereof,
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`Plaintiffs aver as follows.
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`WHEREAS Plaintiffs presently have a submission date of 14 January 2022 for their
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`opening claim construction brief;
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`WHEREAS Plaintiffs’ counsel have a discovery cut-off in another matter that coincides
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`with that date;
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`WHEREAS Plaintiffs’ client representatives are unavailable to review Plaintiffs’ opening
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`claim construction brief during the week of January 17, 2022;
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`Case 1:19-cv-00859-RTH Document 65 Filed 01/12/22 Page 2 of 3
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`WHEREAS Plaintiffs seek an extension to file their opening brief on 24 January 2022 in
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`light of the above-listed conflicts;
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`WHEREAS the Government does not oppose this motion;
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`WHEREFORE, Plaintiffs respectfully move this Court to amend the Scheduling Order as
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`PRIOR DEADLINE
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`NEW DEADLINE
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`14 January 2022
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`24 January 2022
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`18 February 2022
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`28 February 2022
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`4 March 2022
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`14 March 2022
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`18 March 2022
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`28 March 2022
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`25 March 2022
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`4 April 2022
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`1 April 2022
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`11 April 2022
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`To be scheduled
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`To be scheduled
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`15 April 2022
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`25 April 2022
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`follows:
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`EVENT
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`Plaintiffs file their
`opening claim
`construction brief
`The government files
`its responsive claim
`construction brief
`Plaintiffs file their
`reply claim
`construction brief
`The government files
`its sur-reply claim
`construction brief
`The parties submit the
`joint claim
`construction statement
`and propose dates for
`the Markman hearing
`If desired, parties may
`submit joint technical
`tutorial to the Court
`Markman Hearing
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`Deadline for the
`government to produce
`technical documents
`for additional agencies
`named in the second
`amended complaint
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`2
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`Case 1:19-cv-00859-RTH Document 65 Filed 01/12/22 Page 3 of 3
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`Dated: January 12, 2022
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`Respectfully submitted,
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`/s/ Sean T. O’Kelly
`Sean T. O’Kelly
`Gerard M. O’Rourke
`O’KELLY & O’ROURKE, LLC
`824 N. Market Street, Suite 1001A
`Wilmington, DE 19801
`302-778-4000
`sokelly@okorlaw.com
`gorourke@okorlaw.com
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`Attorneys for Plaintiffs
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