Free Stipulation - District Court of Delaware - Delaware

Case 1:05-cv-00918-SLR

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Filed 02/08/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE CHARLES CARL, Plaintiff, v. MBNA, AMERICA BANK, N.A. Defendant. ) ) ) ) ) ) ) ) )

C.A. No.: 05-918

Trial By Jury Demanded

STIPULATED REVISED SCHEDULING ORDER 1. Discovery. (a) 30, 2007. (b) (c) party. (d) (e) Maximum of 10 depositions by plaintiff and 10 by defendant. Each deposition [other than Jane Doe] limited to a maximum of 7 Maximum of 30 interrogatories by each party to any other party. Maximum of 30 requests for admission by each party to any other All discovery shall be commenced in time to be completed by May

hours unless extended by agreement of the parties. (f) Reports from retained experts under Rule 26(a)(2) on issues for

which any party has the burden of proof due by March 1, 2007. Rebuttal expert reports due by May 1, 2007. (g) 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

Case 1:05-cv-00918-SLR

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resolve through a telephone conference, disputes that arise during the course of a deposition and disputes related to entry of a protective order. 2. Summary Judgment Motions: all summary judgment motions

shall be served and filed with an opening brief on or before July 17, 2007. Briefing shall be pursuant to D.Del. LR 7.1.2. No summary judgment motion may be filed more than ten (10) days from above date without leave of the court. 3. 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 7.1.1. 4. Motions in Limine: To be scheduled by the Court after ruling on any

motions for summary judgment. 5. Pretrial Conference: A pretrial conference will be held scheduled by the

Court after ruling on any motions for summary judgment. 6. Trial: To be scheduled by the Court after ruling on any motions for

summary judgment. For the purposes of completing pretrial preparations the parties should plan on being allocated a number of hours in which to present their respective cases.

Case 1:05-cv-00918-SLR

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ABER, GOLDLUST, BAKER & OVER

YOUNG, CONAWAY, STARGATT & TAYLOR, LLP

/s/ Gary W. Aber GARY W. ABER (DSB #754) 702 King Street, Suite 600 P.O. Box 1675 Wilmington, DE 19899 302-472-4900 Attorney for Plaintiff

/s/ Sheldon N. Sandler SHELDON N. SANDLER (DSB #245) 1000 West Street, 17th Floor P.O. Box 391 Wilmington, DE 19899 302-571-6673 Attorney for Defendant

SO ORDERED, this

day of

, 2007.

J.