Free Report of Rule 26(f) Planning Meeting - District Court of Connecticut - Connecticut

Case 3:03-cv-00409-DJS

Document 95-3

Filed 05/23/2008

Page 1 of 2

ATTACHMENT B Plaintiff's Proposed Schedule Discovery 1. Discovery -- both merits and class discovery -- shall commence immediately upon entry of this Order. Merits and class discovery, to the exclusion of expert discovery will be completed (not propounded) by December 22, 2008. 2. Plaintiff's production of documents shall be completed by July 7, 2008.

3. Defendants' production of documents shall be completed by August 7, 2008. Plaintiff is willing to accept a rolling production of Defendants' documents and will work with defendants to minimize the burden and expense associated with production. Still, Plaintiff believes that each party bears its own costs and the Federal Rules of Civil Procedure impose on Defendants the burden and expense of complying with Plaintiffs' discovery requests. 4. Depositions should commence no earlier than August 4, 2008, except that depositions under Fed. R. Civ. P. 30(b)(6) and non-party depositions should commence immediately upon entry of this Order at anytime after May 20, 2008.1 All depositions (except for experts) shall be completed by December 22, 2008. 5. At the close of fact discovery, December 22, 2008, the parties shall confer regarding the scheduling the designation of experts, submission of experts' reports and the depositions of experts. The parties would agree to submit a joint schedule to the regarding expert discovery on or before January 5, 2008. Class Certification 6. Plaintiff shall file his motion for class certification on or before July 16, 2008. Defendants shall be permitted until sixty (60) days following the service of the class certification motion to file their opposition, and Plaintiff should be permitted sixty (60) days after service of an opposition to file his reply. 7. Plaintiff requests that any deadlines established regarding document and deposition class discovery apply equally to the parties. Dispositive Motions 8. The parties agree that dispositive motions shall be filed within thirty (30) following the completion of expert discovery. Any opposition to any dispositive motion shall be filed no later than
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Depositions pertaining to class certification may commence at the time specified below.

Case 3:03-cv-00409-DJS

Document 95-3

Filed 05/23/2008

Page 2 of 2

thirty (30) days after service of any motion. Any reply to such opposition shall be filed no later than twenty (20) days after service of any opposition. Joint Trial Memorandum 9. The parties agree that the joint trial memorandum required by the Standing Order on Trial Memoranda in Civil Cases shall be filed within thirty (30) days of the Court's ruling on the dispositive motions, if any. Absent dispositive motions, the joint trial memorandum shall be due thirty (30) days following the close of expert discovery. Trial Readiness 10. The parties agree that the parties agree that the case will be ready for trial within forty-five (45) days of this Court's ruling on the dispositive motions, if any. Absent dispositive motions, the case will be ready for trial forty-five (45) days following the close of discovery.