Free Proposed Order - District Court of Delaware - Delaware

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Date: December 31, 1969
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State: Delaware
Category: District Court of Delaware
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Case 1 :05-cv-00424-SLR Document 9 Filed 1 1/29/2005 Page 1 of 3
JANE DOE, as the Natural Guardian ) i
of NANCY DOE, a Minor, MARY DOE, ) .
a Minor, and SUSAN DOE, a Minor, )
) C.A. N0. 05-cv~00424 SLR 5
Plaintiffs, ) “ _
) Trial by Jury Demanded
v. )
Defendants. )
At Wilmington this day of , 2005, the parties having satisfied
their obligations under Fed. R. Civ. P. 26(f), and the court having conducted a pretrial scheduling
conference pursuant to Fed. R. Civ. P. 16 and D. Del. LR l6.2(a) and (b),
1. Pre+Discovery Disclosures. The parties will exchange by December 30, 2005
the information required by Fed. R. Civ. P. 26(a)(1) and D. Del. LR 16.2.
2. Discovery.
(a) Discovery will be needed on the following subjects by Defendants:
(I) Whether the plaintiffs experienced mental distress, pain and ‘
suffering, depression, anxiety or panic attacks; and, if so, the cause of such problems;
(2) Whether other students harassed Nancy or Susan Doe, or subjected
Nancy or Susan Doe to derisive comments, noises, or gestures;
(3) Whether Jane Doe interrogated first grade students, and I

Case 1:05-cv-00424-SLR Document 9 Filed 11/29/2005 Page 2 of 3
(4) The information collected by the U.S. Department of Justice, Civil
Rights Division when it investigated at least some of the allegations set forth in the Complaint.
(b) All discovery shall be commenced in time to be completed by June 30, 1
2006. 1 A
(c) Maximum of 25 interrogatories by each party to any other party.
(d) Maximum of 25 requests for admission by each party to any other party.
(e) Maximum of l0 depositions by plaintiff and l0 by defendant. p
(i) Each deposition [other than of Jane Doe] limited to a maximum of 6 hours
unless extended by agreement of parties.
(g) Reports from retained experts under Rule 26(a)(2) on issues for which any 1
party has the burden of proof due by March 30, 2006. Rebuttal expert reports due by April 30,
(h) Discovery Disputes. Any discovery dispute shall be submitted to the
court pursuant to Fed. R. Civ. P. 37. During the course of discovery, each is limited to
two (2) Rule 37 motions. The court shall make itself available, however, to resolve through a
telephone conference, disputes that arise during the course of a deposition and disputes related to
entry of a protective order. 1
3. Joinder of other Parties, Amendment of Pleadings, and Class Certification. 1
All motions to join other parties, amend the pleadings, and certify a class action shall be filed on
or before December 30, 2005.
4. Settlement Conference. Pursuant to 28 U.S.C. § 636, this matter is referred to
Magistrate Judge Thynge for the purposes of exploring ADR. J

Case 1:05-cv-00424-SLR Document 9 Filed 11/29/2005 Page 3 of 3
5. Summary Judgment Motions. All summary judgment motions shall be served
and filed with an opening brief on or before August 1, 2006. Briefing shall be pursuant to L
D. Del. LR 7.1.2. No suirnnaiy judgment motion may be filed more than ten (10) days from the Q
above date without leave of the court. l
6. Applications by Motion. Any application to the court shall be by written motion
filed with the clerk. Unless otherwise requested by the court, counsel shall not deliver copies of
papers or correspondence to chambers. Any non-dispositive motion shall contain the
statement required by D. Del. LR 7.1.1.
L 7. Motions in Limine. All motions in shall be filed on or before [two weeks
before pretrial conference]. All responses to said motions shall be tiled on or before [one
week before pretrial conference]. [
8. Pretrial Conference. A pretrial conference will be held on
at __ _m. in Courtroom 6B, Sixth Floor Federal Building, 844 King Street, Wilmington,
Delaware. The Federal Rules of Civil Procedure and D. Del. LR 16.4 shall govem the pretrial Q
9. Trial. This matter is scheduled for a [day/week] bench/jury trial commencing on
in Courtroom 6B, Sixth Floor Federal Building, 844 King Street,
Wilmington, Delaware. For purposes of completing pretrial preparations, the parties should plan _
on being allocated a total number of hours in which to present their respective cases. I

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