Free Answering Brief in Opposition - District Court of Delaware - Delaware

Case 1:04-cv-01565-SLR Document 47-7 Filed 05/25/2005 Page1 0f4
EXHIBIT J

Case 1:04-cv-01565-SLR Document 47-7 Filed 05/25/2005 Page 2 of 4
O R D E R
At Wilmington this day of 200_, 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. I6 and D. Del. LR l6.2(a)
and (b).
IT IS ORDERED that:
l. Pre·Discovery Disclosures. The parties [have exchanged]
[will exchange by [date) [ the information required by
Fed. R. Civ. P. 26(a)(l) and D. Del. LR l6.2.
2. Discovery.
(a) Discovery will be needed on the following
subjects: (brief description of subjects on which discovery
will be needed}.
(b) All discovery shall be commenced in time to be
completed by [date} .
(c) Maximum of ____ interrogatories by each party to
any other party.
(d) Maximum of _____ requests for admission by each
party to any other party.
(e) Maximum of _____ depositions by plaintiff and ____
by defendant.
(f) Each deposition [other than of ]
limited to a maximum of ____ hours unless extended by agreement

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of parties.
(g) Reports from retained experts under Rule 26(a)(2)
on issues for which any party has the burden of proof due by _____
. Rebuttal expert reports due by .
(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 .
4. Settlement Conference. Pursuant to 28 U.S.C. § 636,
this matter is referred to Magistrate Judge Thynge 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 _____
. 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
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Case 1:04-cv-01565-SLR Document 47-7 Filed 05/25/2005 Page 4 of 4
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.
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 Street, 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/week]
bench/jury trial commencing on in
courtroom 6B, sixth floor Federal Building, 844 King Street,
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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