`
`WILMINGTON
`RODNEY SQUARE
`
`NEW YORK
`ROCKEFELLER CENTER
`
`Adam W. Poff
`P 302.571.6642
`apoff@ycst.com
`
`
`
`August 8, 2023
`
`
`
`VIA CM/ECF & EMAIL
`
`The Honorable Joshua D. Wolson
`United States District Court
`for the Eastern District of Pennsylvania
`James A. Byrne United States Courthouse
`601 Market Street, Room 3809
`Philadelphia, PA 19106
`
`
`
`
`
`Re: Wirtgen America, Inc. v. Caterpillar Inc.
`Case No. 17-770-JDW
`
`Dear Judge Wolson:
`
`We write to confirm that the parties intend to utilize Your Honor’s Policies and Procedures
`
`II(B)(5) (as opposed to the procedure in the Scheduling Order (D.I. 28)) for the briefing and filing
`of summary judgment motions. In order to implement that procedure, the Parties respectfully
`request that the Court order the agreed upon dates and deadlines below. As reflected in the table,
`certain of the proposed dates are extensions of current dates in the Scheduling Order.
`
`
`
`EVENT
`
`CURRENT DATE
`
`PROPOSED DATE
`
`Meet/Confer to Narrow
`Potential Motions
`
`Exchange Statements of
`Undisputed Facts
`
`Exchange of Responsive Fact
`Statements
`
`File Summary Judgment
`Motions with Compiled Fact
`Statements and Joint Exhibits
`
`n/a
`
`n/a
`
`n/a
`
`August 22, 2023
`
`September 7, 2023
`
`September 21, 2023
`
`September 14, 2023
`
`October 5, 2023
`
`Young Conaway Stargatt & Taylor, LLP
`Rodney Square | 1000 North King Street | Wilmington, DE 19801
`P 302.571.6600 F 302.571.1253 YoungConaway.com
`
`
`
`Case 1:17-cv-00770-JDW Document 203 Filed 08/08/23 Page 2 of 2 PageID #: 15643
`
`Young Conaway Stargatt & Taylor, LLP
`The Honorable Joshua D. Wolson
`August 8, 2023
`Page 2
`
`
`File Answering Summary
`Judgment Briefs
`
`File Reply Summary Judgment
`Briefs
`
`October 5, 2023
`
`October 19, 2023
`
`October 19, 2023
`
`November 2, 2023
`
`Summary Judgment Hearing
`
`n/a
`
`TBD
`
`Should Your Honor have any questions about the foregoing, the parties are available at the
`
`Court’s convenience.
`
`
`
`cc: All Counsel of Record (via e-mail)
`
`
`
`
`Respectfully,
`
`/s /Adam W. Poff
`
`Adam W. Poff (No. 3990)
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
