Free Proposed Discovery Plan - District Court of Delaware - Delaware

Case 1:08-cv-00026-GMS

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Filed 07/16/2008

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800 N. King Street Suite 300 Wilmington, DE 19801 Telephone: 302-426-1900 Facsimile: 302-426-9947

Kenneth L. Dorsney.

[email protected]

Campbell & Levine
Attorneys at Law

July 16, 2008 VIA HAND DELIVERY The Honorable Gregory M. Sleet United States District Court for The District of Delaware 844 North King Street Wilmington, DE 19801 RE: Wisnewski et al. v. Ocean Petroleum et al., (GMS)

c.A. No. 08-00026

Dear Judge Sleet: Attached hereto please find a copy of the letter and Rule 26(f) Discovery Plan hand delivered to your chambers on May 12, 2008. If you have any questions, please do not hesitate to contact me.

Sincerely yours,

Kenneth L. Dorsney KLD/smb Enclosure

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EXHIBIT A


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800 N. King Street Suite 300 Wilmington, DE 19801 Telephone: 302-426-1900 Facsimile: 302-426-9947

Kate Schulhaus Keller. [email protected]

Campbell & Levine, LLC
Attorneys at Law

May 12, 2008
VIA HAND DELIVERY The Honorable Gregory M. Sleet United States District Court for the District of Delaware 8-44 North King Street Wilmington, DE 19801

RE:

Wisnewski et al. v. Ocean Petroleum et al.. C.A. No. 08-00026 CGMS)

Dear Judge Sleet: As required by Federal Rule of Civil Procedure 26(f), the attorneys of record for Plaintiffs and Defendants held a conference with respect to their claims and discovery related matters. Enclosed herewith is the proposed Discovery Plan setting forth deadlines for the commencement and completion of discovery, as agreed upon by the parties. The parties respectfully request that Your Honor enter the Discovery Plan governing the timing of discovery. If the Court has any questions or concerns, we remain available.

.,./ ~. J'2 /"/ / --Y' " " { JA tU{;~.- tii1/l '7 UUi~/"Kate Schulhaus Keller

Respectfully submitted,

Enclosures cc: David Malatesta, Esquire (via hand delivery)

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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE


EDWARD WISNIEWSKI and )
MARY WISNIEWSKI, Co-Administrators)
ofthe Estate of Eric E. Wisniewski, ) Deceased, )
Plaintiffs, ) ) v. ) ) OCEAN PETROLEUM, L.L.C., and ) BRUCE PREDEOUX, ) ) Defendants. )


C.A. No.: 1:08-cv-00026 (GMS)
JURY TRIAL DEMANDED


RULE 26(F) DISCOVERY PLAN

This Discovery Plan is based upon the agreement of the parties after having met and conferred pursuant to Federal Rule of Civil Procedure 26(f).
IT IS HEREBY ORDERED that:

1.

The parties shall provide the initial disclosures under Fed. R. Civ. P. 26

(a)(l) no later than twenty-one (21) days after the parties Rule 26(f) discovery planning conference. Any extension ofthe deadline to provide initial disclosures must be by Order ofthe Court and will only be granted for good cause shown. 2. All fact discovery shall be completed no later than one hundred twenty

(120) days after the date of entry ofthis Order. 3. Within sixty (60) days after the completion of the parties' fact discovery,

Plaintiff shall identify and provide its expert reports. 4. Within sixty (60) days after Plaintiff provides its expert reports,

Defendants shall identify and provide their expert reports to Plaintiffs.

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5.

All depositions of Plaintiffs' experts must be conducted within two

hundred ten (210) days after the date of entry of this Order. 6. All depositions of Defendants' experts must be conducted within two

hundred forty (240) days after the date of entry of this Order. 7. The Plaintiff shall immediately notify Chambers upon the settlement,

dismissal or other resolution of this civil matter and shall file with the Court appropriate evidence of such resolution as soon thereafter as is feasible. Plaintiff shall immediately - advise Chambers, in writing, of any occurrenceorcircumstancewhichPlaintiffbelieves may suggest or necessitate the adjournment or other modification of the trial setting. 8. Upon completion of the Scheduling Conference required by Federal Rule

of Civil Procedure 16 and Local Rule 16.2(b), the parties will submit a proposed Scheduling Order in substantial compliance with this Court's form Scheduling Order. 9. Deadlines contained in this Discovery Plan may be extended by

Stipulation between the parties. 10. The Plaintiff shall serve this Discovery Plan on Defendant within five (5) business days after the entry of this Order. Dated: Wilmington, DE Judge Gregory M. Sleet , 2008

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