Free Letter - District Court of Delaware - Delaware

Case 1:08-cv-00014-SLR Document 10 Filed O3/24/2008 Page 1 of 1
BEVERLY L. B 0vE
Attorney at Law Member DE & PA Bars

BEVERLY 1,. nova
vmcsm J. x. immucx, n
March 24, 2008
VIA EFILE & HAND DELIVERY
The Honorable Sue L. Robinson
U.S. District Court for the District of Delaware
844 North King Street
Lock Box 31
Wilmington, DE 19801
RE: Susan Shoemaker v. Chelcie & Stacey McConnell
Civ. No.: 08-014-SLR
Dear Chief Judge Robinson:
Enclosed for the C0urt’s consideration is Plaintiffs Proposed Scheduling Order. The
Scheduling Conference is currently scheduled for Wednesday, March 26, 2008 at 8:30a.m. We
previously sent the drait Scheduling Order to Mr. Casarino, but we have not yet heard from him. I
do understand that Mr. Casarino has been out of town.
If the Court has any questions, I remain available to answer them. I appreciate Your Honor’s
consideration of this matter.
Respectfully submitted,
BLB/kmw n
Enclosure
Cc: Stephen P. Casarino, Esquire

1020 W. 18th Street • P.O. BOX 1607 (302) 777-3500
‘ Wilmington, Delaware 19899 Fax (302) 777-3805

Case 1:08-cv—00014-SLR Document 10-2 Filed 03/24/2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
Susan Shoemaker, : Civ. No.: 08-014-SLR
Plaintiff, :
: Civil Action
v. :
Chelcie McConnell and Stacey McConnell,
Defendants. :
SCHEDULING ORDER
At Wilmington this 26th day of March, 2008, 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. l6 and D. Del. LR 16.2(a) and (b).
ITIS ORDERED that:
1. Pre-Discovery Disclosures. The parties will exchange by April 28, 2008 the
information required by Fed. R. Civ. P. 26(a)(l) and D. Del. LR 16.2.
2. Discovery.
(a) Discovery will be needed on the following subjects: liability, depositions,
written discovery from parties, and medical discovery.
(b) All discovery shall be commenced in time to be completed by December
26, 2008.
(c) Maximum of 50 interrogatories by each party to any other party.
(d) Maximum of 50 requests for admission by each party to any other party.
(e) Maximum of 5 depositions by plaintiff and 5 by defendants.
(f) Each deposition limited to a maximum of 2 hours unless extended by
I agreement of parties.

Case 1:08-cv—00014-SLR Document 10-2 Filed 03/24/2008 Page 2 of 3
(g) Reports from retained experts under Rule 26(a)(2) on issues for wich any
party has the burden of proof due by June 26, 2008. Rebuttal expert reports due by August 26,
2008.
(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 party 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.
3. Joinder of other Parties, Amendment of Pleadings, and Class Certification. All
motions to join other parties, amend the pleadings, and certify a class action shall be filed on or
before June 26, 2008.
4. Settlement Conference. Pursuant to 28 U.S.C. § 636, this matter is referred to a
Magistrate Judge for the purposes of exploring ADR.
5. Summary Judgment Motions. All summary judgment motions shall be served and
filed with an opening brief on or before January 26, 2009. Briefing shall be pursuant to D. Del.
LR 7.1.2. No summary judgment motion may be filed more than ten (10) days from the above
date without leave of the court.
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.l.l.

Case 1:08-cv—00014-SLR Document 10-2 Filed 03/24/2008 Page 3 of 3
7. Motions in Limine. All motions Q Qrg 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 in courtroom ,
Wilmington, Delaware. The Federal Rules of Civil Procedure and D. Del. LR 16.4 shall govern
the pretrial conference.
9. Trial. This matter is scheduled for a trial commencing
on in courtroom ,
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.


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