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

Case 3:03-cv-00409-DJS

Document 95-2

Filed 05/23/2008

Page 1 of 2

ATTACHMENT A Defendants' Proposed Schedule 1. Defendants shall file their Answers five days after the Court lifts the discretionary stay.

2. The parties shall exchange Initial Disclosures ten days after the Court lifts the discretionary stay. 3. Plaintiffs shall have until the later of May 30, 2008, or five days after Defendants file their Answers to join additional parties or amend the pleadings. 4. Class certification fact discovery shall commence immediately upon entry of this Order, and shall conclude by August 29, 2008. 5. Plaintiffs shall file their motion for class certification by September 29, 2008.

6. Defendants shall file any opposition to Plaintiffs' motion for class certification by November 28, 2008. 7. Plaintiffs shall file their reply papers supporting class certification by December 19, 2008. 8. 9. The Court shall conduct a hearing on class certification as soon as practicable. Merits discovery shall commence upon the Court deciding the class certification issue.

10. Plaintiffs' expert report(s) on the merits shall be served within 20 days of the conclusion of discovery. 11. Defendants shall depose Plaintiffs' expert(s) on the merits within 30 days of submission of the Plaintiffs' expert report. 12. Defendants' expert reports on the merits shall be served within 30 days of the deposition of Plaintiffs' expert(s). 13. Plaintiffs shall depose Defendants' experts on the merits within 30 days of submission of Defendants' expert report. 14. Plaintiffs shall file any expert rebuttal reports on the merits within 30 days of the deposition of Defendants' expert(s). 15. The parties shall file any motions for summary judgment or other dispositive motions within 30 days of submission of Plaintiffs' expert rebuttal report. The local rules shall apply to deadlines relating to summary judgment and similarly dispositive papers. 16. The parties shall file all motions in limine within 30 days of the deadline for filing of summary judgment or other dispositive motions. 17. The parties shall file their trial briefs, and exchange witness and exhibit lists within 14 days of the deadline for filing all motions in limine.

Case 3:03-cv-00409-DJS

Document 95-2

Filed 05/23/2008

Page 2 of 2

18. This case shall be ready for trial within 14 days of the deadline for exchanging witness and exhibit lists. [Assuming that the Court decides the class certification issue within sixty (60) days of that issue being submitted to the Court, Defendants anticipate that the case would be ready for trial on or about December 16, 2009.] 19. Defendants' proposed schedule may be modified for good cause shown and/or the consent of the parties subject to Court approval.

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