Carro v. Barra et al

Filing 23

ORDER setting deadlines., (Amended Complaint to be filed by 3/6/2017, Response to the complaint due by 4/5/2017), ( Motion to Dismiss (if any) to be filed by 4/5/2017, Response due by 5/5/2017, Reply due by 5/26/2017) Signed by District Judge Robert H. Cleland. (LWag)

IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN

DANIEL J. CARRO,
Plaintiff,
v.
MARY T. BARRA, DANIEL F.
AKERSON, MICHAEL P. MILLIKIN,
AND JOHN CALABRESE,

No. 16-cv-10479-RHC

Defendants,
-andGENERAL MOTORS COMPANY,
Nominal Defendant.

JOINT SCHEDULING ORDER
Pursuant to the Court’s January 10, 2017, Order (Docket #20), the parties to the
above-captioned action have met and conferred regarding scheduling and jointly submit
the attached proposed scheduling order to address the immediate next steps in the
litigation. As required by the order, the parties have also met and conferred regarding
Rule 26(f) issues, including those identified in the Court’s Sample Outline for a Rule
26(f) Plan and Status Report. Given the early stage of the litigation and plaintiff’s intent
to file an amended complaint, the parties submit that it may be premature to address
many of the issues set out in the sample outline. Of course, if the Court did anticipate

the filing of a formal Rule 26(f) report, the parties will do so promptly and will be
prepared to discuss the issues at the Scheduling Conference set for February 7, 2017.
The parties jointly submit the attached proposed order providing a schedule for
plaintiff’s filing of his amended complaint and defendants’ response thereto.
/s/ Andrew J. Morganti
Andrew J. Morganti (P57989)
MORGANTI LEGAL
535 Griswold Street, Suite 111-181
Detroit, MI 48226
[phone]
[phone] (Fax)
[e-mail]

/s/ Raymond W. Henney
Raymond W. Henney (P35860)
HONIGMAN MILLER SCHWARTZ
AND
COHN LLP
660 Woodward Avenue, Suite 2290
Detroit, MI 48226
[phone]
[e-mail]

Local Counsel for Plaintiff
SCHUBERT JONCKHEER &
KOLBE LLP
Robert C. Schubert
Willem F. Jonckheer
Three Embarcadero Center, Suite 1650
San Francisco, CA 94111
[phone]
[phone] (Fax)
[e-mail]
[e-mail]

KIRKLAND & ELLIS LLP
Robert J. Kopecky (IL #3125334)
Joshua Z. Rabinovitz (IL #6272899)
300 N. LaSalle Street
Chicago, IL 60654
[phone]
[e-mail]
[e-mail]
Counsel for General Motors
Company

Counsel for Plaintiff

2

s/ Daniel J. LaCombe
Daniel J. LaCombe (P38602)
BARRIS, SOTT, DENN & DRIKER
PLLC
211 W. Fort Street, 15th Floor
Detroit, MI 48226
[phone]
[e-mail]
Counsel for the Individual
Defendants

3

UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION

DANIEL J. CARRO,
Plaintiff,
No. 16-cv-10479-RHC

v.
MARY T. BARRA, et al.,
Defendants,

SCHEDULING ORDER
The Court hereby ORDERS, accepting the proposal of the parties to this
case, the following schedule:
1.

Plaintiff shall file his amended complaint on or before March 6, 2017.

2.

Defendants shall file their response to the amended complaint on or

before April 5, 2017.
3.

If Defendants file a motion to dismiss, Plaintiff shall file any

opposition brief on or before May 5, 2017, and Defendants shall file any reply
brief on or before May 26, 2017.

S/Robert H. Cleland
ROBERT H. CLELAND
UNITED STATES DISTRICT JUDGE

Dated: January 26, 2017

I hereby certify that a copy of the foregoing document was mailed to counsel of record
and/or pro se parties on this date, January 26, 2017, by electronic and/or ordinary mail.

S/Lisa Wagner
Case Manager and Deputy Clerk
[phone]

5