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STIPULATED REQUEST TO EXTEND 

DEADLINE FOR SUBMITTING RULE 706 

EXPERTS - Case No Case No. C 09-02737 WHA. 

Tharan Gregory Lanier (State Bar No. 138784) 

tglanier@jonesday.com 

Gregory L. Lippetz (State Bar No. 154228) 

glippetz@jonesday.com 

Daniel H. Mao (State Bar No. 221539) 

dhmao@jonesday.com 

Joe C. Liu (State Bar No. 237356) 

jcliu@jonesday.com 

Peter D. Nestor (State Bar No. 262253) 

pnestor@jonesday.com 

JONES DAY 

1755 Embarcadero Road 

Palo Alto, CA 94303 

Telephone: 650-739-3939 

Facsimile: 650-739-3900 

Attorneys for Plaintiff/Counterdefendant 

SANDISK CORPORATION 

Bruce S. Sostek (pro hac vice) 

(bruce.sostek@tklaw.com) 

Jane Politz Brandt (pro hac vice) 

(jane.brandt@tklaw.com) 

Herbert J. Hammond (pro hac vice) 

(herbert.hammond@tklaw.com 

Max Ciccarelli (pro hac vice) 

max.ciccarelli@tklaw.com 

Richard L. Wynne, Jr. (pro hac vice) 

richard.wynne@tklaw.com 

THOMPSON & KNIGHT LLP 

1722 Routh St., Suite 1500 

Dallas, Texas 75201 

Telephone: (214) 969-1700 

Facsimile: (214) 959-1751 

Attorneys for Defendant/Counterclaimant 

LSI CORPORATION and Counterclaimant 

AGERE SYSTEMS INC. 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

SANDISK CORPORATION, 

Plaintiff, 

v. 

LSI CORPORATION, 

Defendant. 

LSI CORPORATION AND AGERE 

SYSTEMS INC., 

Counterclaimants, 

v. 

SANDISK CORPORATION, 

Counterdefendant. 

Case No. C09-02737 WHA 

STIPULATED REQUEST TO EXTEND 

DEADLINE FOR SUBMITTING RULE 

706 EXPERTS PURSUANT TO COURT’S 

DECEMBER 1 AND JANUARY 25 

ORDERS AND [PROPOSED] ORDER 

Judge: Hon. William Alsup 

Courtroom 9, 19th Floor 

Date Filed: June 19, 2009 

Trial Date: November 8, 2010 

Case 3:09-cv-02737-WHA Document 80 Filed 02/03/10 Page 1 of 4 Case3:09-cv-02737-WHA Document79 Filed02/02/10 Page1 of 4
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- 1 - 

STIPULATED REQUEST TO EXTEND 

DEADLINE FOR SUBMITTING RULE 706 

EXPERTS - Case No Case No. C 09-02737 WHA. 

Pursuant to Civil L.R. 6-2 and Civil L.R. 7-12, Plaintiff-Counterdefendant SanDisk 

Corporation (“SanDisk”) and Defendant-Counterplaintiff LSI Corporation and Counterplaintiff 

Agere Systems Inc. (collectively “LSI”), through their respective counsel, hereby make the 

following Joint Stipulated Request for an Order to extend the deadline for the parties to submit 

proposed Rule 706 candidates pursuant to the Court’s December 1, 2009 and January 24, 2010 

Orders. 

On December 1, 2009 the Court issued the “Order Regarding Rule 706 Expert” (Dkt. No. 

65) requiring the parties to submit two proposed Rule 706 candidates by January 22, 2010. On 

January 22, 2010 the parties submitted two proposed candidates. On January 25, 2010 the Court 

issued the “Supplemental Order Regarding Rule 706 Expert” (Dkt. No. 75), in which the Court 

clarified the type of candidates that it was seeking. 

Although the parties have been working diligently to identify qualified Rule 706 experts 

from this district, they have been unable to complete their search for and vetting of appropriate 

candidates. The parties have faced a multitude of obstacles, including the limited number of 

qualified experts in this district, the limited availability of some candidates, and the fact that some 

candidates have been less responsive than the parties had hoped. 

Accordingly, the parties are seeking seven (7) additional business days to Friday, 

February 12, 2010, within which to identify, vet, and submit two qualified candidates. 

This Stipulation will not affect other dates in the case schedule, including the Tutorial 

scheduled for March 3, 2010 or the Claim Construction hearing that is scheduled for March 11, 

2010. 

THE PARTIES HEREBY JOINTLY STIPULATE AND PROPOSE THAT: 

The deadline for submitting proposed Rule 706 experts be extended to February 12, 2010. 

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STIPULATED REQUEST TO EXTEND 

DEADLINE FOR SUBMITTING RULE 706 

EXPERTS - Case No Case No. C 09-02737 WHA. 

Dated: February 2, 2010 JONES DAY 

By: /s/ Joe C. Liu

 Joe C. Liu 

Attorneys for Plaintiff 

SANDISK CORPORATION 

In accordance with General Order No. 45, Section X(B), the above signatory attests that 

concurrence in the filing of this document has been obtained from the signatory below. 

Dated: February 2, 2010 THOMPSON & KNIGHT LLP 

By: /s/ Max Ciccarelli

 Max Ciccarelli 

Attorneys for LSI CORPORATION AND 

AGERE SYSTEMS INC. 

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- 3 - 

STIPULATED REQUEST TO EXTEND 

DEADLINE FOR SUBMITTING RULE 706 

EXPERTS - Case No Case No. C 09-02737 WHA. 

[PROPOSED] ORDER 

Pursuant to the Stipulation above, the Court hereby extends the deadline for the parties to 

submit the names of two qualified Rule 706 experts to 5:00 p.m. on February 12, 2010. 

PURSUANT TO THE STIPULATION, IT IS SO ORDERED. 

Dated:__________________ By___________________________ 

THE HONORABLE WILLIAM ALSUP 

United States District Judge 

Northern District of California 

SVI-77323v1 

Case3:09-cv-02737-WHA Document79 Filed02/02/10 Page4 of 4

noon February 3, 2010.

U

NITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

IT IS SO ORDERED

Judge William Alsup

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