Free Letter - District Court of Delaware - Delaware

Case 1:07-cv-00362-SLR Document 10 Filed 09/18/2007 Page 1 of 1
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JAMES M. BAKER Q
MAYOR LOUIS L. REDDING · CITY/COUNTY BUILDING
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September 18, 2007 -
VIA E-FILING AND HAND DELIVERY
The Honorable Sue L. Robinson
District of Delaware
844 N. King St. ‘ _ - _
Wilmington, DE 19801 A
Re: Elizabeth A. Huovinen v. City of Wilmington, et al.,
C.A. No. 07-362 {SLR)
Dear Judge Robinson: U c
Per the Court’s Order dated August 22, 2007, please find enclosed a proposed
discovery plan and order agreed to by both parties. The parties are prepared to discuss
the discovery plan during the telephonic scheduling conference presently scheduled for
Thursday, September 20, 2007 at 8:30 a.m.
Respectfully,
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Gary W. Lipkin (#4044)
Assistant City Solicitor
Enclosure _
cc: Clerk of Court (via e-filing, with enclosure)
Steven F. Mones, Esq. (via e-filing, with enclosure)

Case 1 :07-cv—00362-SLR Document 10-2 Filed 09/18/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
ELIZABETH A. HUOVINEN )
(f/k/a Elizabeth Taylor), )
Plaintiff, g
v. g C.A. No. 07-362 SLR
CITY OF WILMINGTON and g JURY TRIAL DEMANDED
KENNETH BUKOWSKI, )
Defendants. g
EE
At Wilmington this _ day of September 2007, the parties having satisfied
their obligations under Fed. R. Civ. P. 26(i), and the Court having conducted a pretrial
scheduling conference pursuant to Fed. R. Civ. P. 16 and D. Del. LR 16.2 (a) and (b).
IT IS ORDERED that:
1. Pre-Discovery Disclosures. The parties have exchanged 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: (a) whether
Defendants subjected Plaintiff to gender-based discrimination and sexual harassment; (b)
whether the City of Wilmington retaliated against Plaintiff for tiling a Charge with the
Delaware Department of Labor; (c) Plaintiff’s allegation of battery and other torts; (d) all
damages allegedly suffered by Plaintiff; and (e) applicable defenses to Plaintiff’s claims.
b. All discovery shall be commenced in time to be completed by
February 29, 2008.
c. Maximum of 50 interrogatories by each party to any other party.
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Case 1 :07-cv—00362-SLB Document 10-2 Filed 09/18/2007 Page 2 of 3
d. Maximmn of 50 requests for admission by each party to any other
Paw-
e. Maximum of one deposition of Plaintiff and one deposition of
Defendant, Kenneth Bukowski.
f. Each deposition [other than those of Plaintiff or Defendant
Kenneth Bukowski] shall be limited to a maximum of 6 hours unless extended by
agreement of the parties.
g. Reports from retained experts under Rule 26(a)(2) on issues for
which any party has the burden of proof shall be due by March 31, 2008. Rebuttal expert
reports shall be due by April 30, 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 January 4, 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 May 30, 2008. Briefing shall be
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Case 1 :07-cv—00362-SLR Document 10-2 Filed 09/18/2007 Page 3 of 3
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 motions
shall contain the statement required by D. Del. LR 7.1.1.
7. Motions in Limine. All motions in limine shall be filed on or before two
weeks before pretrial conference. All responses to said motions shall be filed on or
before one week before pretrial conference.
8. Pretrial Conference. A pretrial conference will be held on
at _ _.m. in Courtroom 6B, sixth floor, Federal
Building, 844 King St., 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 __ day jury trial commencing on
in courtroom 6B, sixth floor, Federal Building, 844 King
St., 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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