Free Reply to Response to Motion - District Court of Delaware - Delaware

Case 1:04-cv-01416-JJF Document 63-2 Filed 12/15/2005 Page1 012

Case 1:04-cv-01416-JJF Document 63-2 Filed 12/15/2005 Page 2 of 2
Pamela A. Nagle
From: Harvey Levin {[email protected]]
Sent: Friday, November t1, 2005 11:41 AM
To: James Heisman
Subject: Pretrial Scheduling
Jim,
liust took a look at the Scheduling Order. Expert reports for the party bearing the burden of proof
are due 1l/30, answering expert reports 12/30 and expert depositions within 30 days of receipt of the
reports. Dispositive motions are due Jan. 30. i-low about if we push everything lnitialiy five weeks,
so that opening expert reports would be due the end ofthe first week in January (the Sth). That
would allow us a couple weeks in December for depositions before opening expert reports.
Answering expert reports would be due 30 days after the opening reports, Feb. 6. We could have
January and February for expert and other depositions, finishing them by Feb. 24 (or earlier), and
have a dispositive rnotions deadline of Mar. 6 or two weeks after depositions end, whichever is later,
so at least the motions (though obviously not opps and replies) would be filed by the Mar. 8 pretrial
conference. For your consideration.
Harvey
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i