The opinion of the court was delivered by: Honorable Maria Elena James United States Magistrate Judge
E-FILING CASE STATUS STATEMENT, STIPULATION AND [PROPOSED] ORDER
Pursuant to this Court's order dated January 27, 2009, the parties jointly submit the following joint status statement:
A. The Status Of The Case
The parties have completed most, but not all, of the discovery necessary to allow for fair disposition of the case. The parties request that the following additional discovery be permitted and that the dates in this Court's previously-filed scheduling order be adjusted to permit such discovery as follows:
The parties request permission to take the depositions of the following percipient witnesses:
Keca Carpenter, Dr. Kimberly Kodger, Gregory Porter, Anthony Eckert, Deborah Lorance, Kevin Mitchel, Suzanne Mitchel (completion of previously-started deposition), and Amy Noble. These depositions will be completed on or before March 3, 2009. The parties request permission to take the depositions of the following expert witnesses: Bernard Rappaport, M.D. (or Jeffrey Gould, M.D.) and Karen Carlquist-Hernandez, Ed.D. These depositions will be completed on or before April 3, 2009. The parties also will exchange any responses to previously-served written discovery on or before February 20, 2009.
Plaintiff will submit to an Independent Medical Examination on or before March 25, 2009.
B. Referral For Further Settlement Conference
The parties agree that a further settlement conference before Judge Chen would be beneficial if scheduled to take place after the ruling on any dispositive motions, if filed.
The parties request that the deadline for filing dispositive motions be extended to March 5, 2009-- any motion filed on or before that to be heard April 9, 2009. The dates for the remaining pretrial and trial dates shall be addressed in a separate order. final pretrial and the trial date and will remain unchanged. Nevertheless, the remaining deadlines will be continued for two weeks; in particular: the last day to meet and confer regarding pretrial filings will be moved to April 16th, the last day to file pretrial documents will be moved to April 30, 2009 and the last day to file jury verdict forms, voir dire and jury instructions will be May 14, 2009. The date of the preliminary pretrial will be May 14, 2009.
JOSEPH P. RUSSONIELLO Mark Schallert, Esq. United States Attorney Unable ...