STIPULATION AND [PROPOSED] ORDER RE PRETRIAL CASE MANAGEMENT DEADLINES JURY TRIAL DEMANDED
IT IS HEREBY STIPULATED AND AGREED by and among the parties hereto, through their attorneys of record, that:
(i) In order to avoid the expense and time of potentially unnecessary expert discovery and dispositive motion practice, and
(ii) To facilitate the mediation scheduled for March 23, 2010, subject to the Court's approval, the Order Following Further Case Management Conference dated November 18 2009 (Doc #226), is hereby amended as follows:
1. ALTERNATIVE DISPUTE RESOLUTION -- MEDIATION
All parties have agreed to privately mediate this case and attend a full-day mediation scheduled before the Honorable Rebecca Westerfield (of JAMS) on March 23, 2010.
a. Plaintiffs shall disclose the names of their rebuttal experts by February 19, 2010;
b. Rebuttal reports shall be produced by February 22, 2010; and c. All expert discovery, including depositions of experts, shall be completed no later than May 7, 2010.
a. The last day for hearing dispositive motions shall be June 15, 2010, 9:00a.m, without prejudice to motions being heard on an earlier date.
b. The parties agree to file their dispositive motions at least 50 days before the noticed hearing date.
c. Responsive papers to dispositive motions shall be filed 25 days before the noticed hearing date.
d. Reply papers in support of dispositive motions shall be filed 14 days before ...