Free Other Notice - District Court of Arizona - Arizona

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SUSAN MARTIN (AZ#014226) DANIEL L. BONNETT (AZ#014127) JENNIFER KROLL (AZ#019859) MARTIN & BONNETT, P.L.L.C. 3300 N. Central Avenue, Suite 1720 Phoenix, Arizona 85012-2517 Telephone: (602) 240-6900 [email protected] [email protected] [email protected] Attorneys for Plaintiffs

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IN THE UNITED STATES DISTRICT COURT
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FOR THE DISTRICT OF ARIZONA
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Barbara Allen; Richard Dippold; Melvin Jones; Donald McCarty; Richard Scates and Walter G. West, individually and on behalf of all others similarly situated, Plaintiffs,

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vs.
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Honeywell Retirement Earnings Plan; Honeywell Secured Benefit Plan; Plan Administrator of Honeywell Retirement Earnings Plan; and Plan Administrator of Honeywell Secured Benefit Plan, Defendants.

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) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

No. CV04-0424 PHX ROS

PLAINTIFFS NOTICE OF FILING REVISED PROPOSED SCHEDULING ORDER

In accordance with the Court s Order dated October 4, 2006, (Doc. 242), Plaintiffs and Defendants filed a Proposed Scheduling Order on October 10, 2006. (Doc. 246.) On October 25, 2006, Plaintiffs received the latest compact disc containing portions of the electronic data that Defendants furnished in response to Plaintiffs discovery requests. A large portion of the electronic data produced by Defendants was received by Plaintiffs on September 27 and 28, 2006 and October 5, 2006. Plaintiffs have been working diligently to produce expert disclosures.

However, Plaintiffs have encountered significant delays and unanticipated problems in analyzing the data provided by Defendants due to the condition and form of the

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data produced that Defendants have averred is the form in which the data was or is maintained. As a result of these data issues, some of the dates proposed by Plaintiffs in the Proposed Scheduling Order submitted on October 10, 2006 need to be revised. Plaintiffs hereby submit a revised proposed scheduling order, modifying the dates Plaintiffs proposed in paragraphs E, F, G and L. The revised Proposed Scheduling Order, which adjusts only certain dates proposed by Plaintiffs, is attached hereto as Exhibit A. The revised dates proposed by Plaintiffs continue to comply with the Court s directive that the Proposed Scheduling Order will allow completion of this matter within one calendar year. (Doc. 242.) Respectfully submitted this 28th day of November, 2006. MARTIN & BONNETT, P.L.L.C. By: s/Jennifer Kroll Susan Martin Daniel L. Bonnett Jennifer L. Kroll 3300 North Central Avenue, Suite 1720 Phoenix, AZ 85012-2517 (602) 240-6900 Attorneys for Plaintiffs

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CERTIFICATE OF SERVICE I hereby certify that on November 28, 2006, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: David B. Rosenbaum Dawn L. Dauphine Osborn Maledon, P.A. 2929 North Central Ave., Suite 2100 Phoenix, AZ 85012-2794 and

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Michael Banks William Delaney John G. Ferreira. Azeez Hayne. Morgan Lewis & Bockius LLP 1701 Market Street Philadelphia, PA 19103 Amy Covert Proskauer Rose LLP One Newark Center, 18th Floor Newark , NJ 07102-5211 Howard Shapiro Proskauer Rose, LLP 909 Poydras St., Suite 1100 New Orleans, LA 70112 Attorneys for the Defendants

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s/T.Mahabir

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