Proposed Discovery Plan Scheduling Order (Mag. Judge Kuo)

Rev. 8-10-18 PROPOSED DISCOVERY PLAN DONE NOT APPLICABLE DATE A. ACTIONS REQUIRED BEFORE THE INITIAL CONFERENCE 1. Rule 26(f) Conference held 2. Rule 26(a)(1) disclosures exchanged 3. Requests made: a. Medical records authorization b. Section 160.50 releases for arrest records c. Identification of John Doe/Jane Doe defendants d. Proposed Stipulation of Confidentiality 4. Procedures for producing Electronically Stored Information (ESI) discussed B. SETTLEMENT 1. Plaintiff to make settlement demand 2. Defendant to make settlement offer 3. Referral to EDNY mediation program pursuant to Local Rule 83.8? (If yes, enter date to be completed) 4. Settlement Conference C. PROPOSED DEADLINES 1. Motion to join new parties or amend pleadings 2. Initial documents requests and interrogatories 3. All fact discovery to be completed (including disclosure of medical records) 4. Joint status report certifying close of fact discovery and indicating whether expert discovery is needed 5. Expert discovery (only if needed) Check here if not applicable American LegalNet, Inc. www.FormsWorkFlow.com Rev. 8-10-18 Plaintiff expert proposed field of expertise: Defendant expert proposed field of expertise: DONE NOT APPLICABLE DATE a. Case-in-chief expert report due b. Rebuttal expert report due c. Depositions of experts to be completed 6. Completion of ALL DISCOVERY 7. Joint status report certifying close of all discovery and indicating whether dispositive motion is anticipated 8. If District Judge requires Pre-Motion Conference, date to make request 9. If District Judge does not require Pre-Motion Conference, date to submit briefing schedule 10. Joint Pre-Trial Order due (if no dispositive motion filed) D. CONSENT TO MAGISTRATE JUDGE JURISDICTION 1. All parties consent to Magistrate Judge jurisdiction for dispositive motion? Yes No 2. All parties consent to Magistrate Judge jurisdiction for trial? Yes No E. COLLECTIVE ACTION AND C LASS ACTION MOTIONS ONLY 1. Motion for collective action certification in FLSA cases a. Response due b. Reply due 2. Motion for Rule 23 class certification a. Response due b. Reply due This Scheduling Order may be altered or amended only upon a showing of good cause based on circumstances not foreseeable as of the date of this order. SO ORDERED: PEGGY KUO Date United States Magistrate Judge American LegalNet, Inc. www.FormsWorkFlow.com