Case 3:03-cv-00630-DJS Document 80 Filed 11/05/2004 Page 1 of 4
UNITED STATES DISTRICT COIRT
DISTRICT OF CONNECTICIJT
MARIO RICHARDS : CIVIL ACTION NOA
PLAINTIFF : 3:03 C\/00630 (DIS)
COMPUTER SCIENCES CORPORATION
: NOVEMBER 5, 2004
DEFENDANTS PROPOSED SCHEDULING PLAN
Pursuant to Order of the Court, Defendant hereby submits this proposed
scheduling plan. Despite lengthy discussions between counsel, the parties could not
agree on a substantial nurnber of issues relating to the scheduling plan and Defendant
therefore submits its own plan,
A. Notice and Consent
l. Notice and consent forms to be sent to Level I and II Help Desk
Customer Support Analysts of CSC’s Global Infrastructure Solutions Division (CSAS) at
locations and facilities in the United States shall be presented to the Court for approval on
or before December 7, 2004.
2r Plaintiff shall send notice and consent forms to those persons
whose names and addresses are provided by the Defendant on or before 45 days after
Court approval of the notice and consent forms.
3i Any notice sent to such persons inust be approved by the Court in
Case 3:03-cv-00630-DJS Document 80 Filed 11/05/2004 Page 2 of 4
B. Opt-In Plaintiffs
Opt—In plaintiffs shall opt—in to this case within 60 days of receipt of
l notice of the right to Opt-In.
C. Settlement Conference/Mediation
The parties requests a settlement conference before a Magistrate Judge at
the end ofthe opt in period.
D. Discovery and Depositions
Discovery shall close on September I5, 2005.
E. Rule 26 Disclosures
The parties shall supplement their Rule 26 disclosures by no later than 30
days prior to the close of discovery.
F. Expert Witnesses
The Plaintiff shall disclose experts and reports on or before 90 days
before the close of discovery. Defendant shall disclose experts and reports on or before
45 days before the close of discovery. The parties shall depose experts on or before the
close of discovery.
G. Motions Relating to the Class
Defendant shall have until 60 days after tl1e close of discovery to file a
Motion to Decertify this matter as a collective action.
H. Dispositive Motions
Defendant shall have until 60 days after the Court’s ruling on a Motion
to Decertify, or ifho such Motion is tiled, until 60 days after the close of discovery to
tile Dispositive Motions.
Case 3:03-cv-00630-DJS Document 80 Filed 11/05/2004 Page 3 of 4
I. Rule 16 Conference
Defendant requests a Rule 16 conference as soon as practicable so that the
parties may discuss pending issues with the Court.
Tasos C. Paindiris (ct 16739)
William J. Anthony (ct 17865)
Jackson Lewis LLP
55 Farmington Avenue, Suite i200
Hartford, CT 06105
Telt (860) 522-0404
Lisa A. Schreter (ct 17647)
J ackson Lewis LLP
245 Peachtree Center Avenue, NNE.
1900 Marquis One Tower
Atlanta, GA 30303»1226
Tel. (404) 52543200
Fax. (404) 525-1173
Case 3:03-cv-00630-DJS Document 80 Filed 11/05/2004 Page 4 of 4
CERTIFICATION OF SERVICE
This is to certify that a copy of the foregoing was sent by first class iiiail,
postage prepaid, on this Sth dey of November, 2004, to the following:
Michael J. Melly, Esq,
BElI`IIH'llI(, Gizmacoplos, Bartiriik, Bartimik & Grater, PC.
100 Fort Hill Rd,.
Groton, CT 06340
Tasos C. Pamdiiés