Ostergren v. McDonnell

Filing 32

Consent MOTION for Discovery Plan Adjustment by Robert F. McDonnell. (Attachments: # 1 Proposed Order)(Ingold, James)

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division ) ) ) ) ) ) Civil Action No. 3:08cv362 ) ) ) ) BETTY J. OSTERGREN, Plaintiff, v. ROBERT F. MCDONNELL, Defendant. CONSENT MOTION The parties, jointly by their respective counsel, hereby respectfully propose this adjusted plan to govern discovery in this litigation: (1) The parties agree to disclose all exhibits, except for rebuttal exhibits, and all witnesses (including name, address, telephone and matters on which they are expected to testify), except for expert and rebuttal witnesses, by December 17, 2008; (2) The parties agree to disclose all expert testimony and rebuttal witnesses/exhibits by January 9, 2009; (3) The parties agree to complete all depositions by February 6, 2009. Error! Unknown document property name. WE ASK FOR THIS: _______/s/______________________ Rebecca K. Glenberg Virginia Bar number 44099 ACLU of Virginia Foundation, Inc. 530 E. Main Street, Suite 310 Richmond, Virginia 23219 (804) 644-8080 (804) 649-2733 (facsimile) rglenberg@acluva.org. Counsel for Plaintiff _________________________ James V. Ingold Virginia Bar number 31825 Office of the Attorney General 900 East Main Street Richmond, Virginia 23219 (804) 786 3860 (804) 371 2087 (facsimile) JIngold@oag.state.va.us Counsel for Defendant 2 Error! Unknown document property name.