St. Louis Cardinals, LLC v. Lewis

Filing 25

JOINT SCHEDULING PLAN by Plaintiff St. Louis Cardinals, LLC, Defendant Douglas J. Lewis.. (Clifford, Nicholas)

St. Louis Cardinals, LLC v. Lewis

Doc. 25

Case 4:07-cv-00473-CEJ

Document 25

Filed 08/06/2007

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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION ) ) ) Plaintiff, ) ) vs. ) DOUGLAS J. LEWIS d/b/a STL PRODUCTS ) ) ) Defendant. ) ST. LOUIS CARDINALS, LLC

No. 4:07-CV-473 (CEJ)

REVISED JOINT PROPOSED SCHEDULING PLAN COME NOW the parties to this action and, pursuant to the Court's Order dated March 28, 2007, submit the following Revised Joint Proposed Scheduling Plan: 1. 2. A Track 2 (Standard) assignment is appropriate. The parties must file all motions for joinder of additional parties and amendment

of pleadings by September 16, 2007. 3. Discovery plan a. by October 1, 2007. b. below. c. The presumptive limits of ten (10) fact witness depositions per party as set Discovery shall not be conducted in phases or limited, except as set forth The parties shall make the disclosures required by Fed. R. Civ. P. 26(a)(1)

forth in Fed. R. Civ. P. 30(a)(2)(A) and twenty-five (25) interrogatories per party as set forth in Fed. R. Civ. P. 33(a) should apply in this case. d. e. No physical or mental examinations of parties are necessary in this case. The parties do not presently anticipate any issues relating to disclosure or

discovery of electronically stored information, including the form or forms in which it should be

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Case 4:07-cv-00473-CEJ

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produced. 4. The parties intend to conduct settlement discussions directly at the present time

without the assistance of a mediator. The parties will notify the Court in the future should they believe that the assistance of a mediator would be helpful. 5. Expert Discovery a. Each party shall disclose its expert witnesses' identities and provide the

reports required by Fed. R. Civ. P. 26(a)(2), by October 8, 2007. b. Each party shall disclose its rebuttal expert witness' identities and provide

their reports, by November 5, 2007. c. December 17, 2007. d. December 17, 2007. 6. 7. 8. Dispositive motions shall be filed by March 10, 2008. The case should reasonably be expected to be ready for trial by June 16, 2008. The parties estimate that the case will take approximately three (3) days to try. All discovery, including expert discovery, shall be completed by Each party shall make their respective experts available for deposition by

Respectfully submitted, ARMSTRONG TEASDALE LLP Attorneys for Plaintiff DOUGLAS J. LEWIS

By: /s/ Nicholas B. Clifford, Jr. By: /s/ Douglas J. Lewis, by NBC w/ permission Nicholas B. Clifford, Jr. #36551 4143 Fox Crossing One Metropolitan Square, Suite 2600 St. Louis, Missouri 63034-2009 St. Louis, Missouri 63102-2740 [phone] [phone] (facsimile) [e-mail]

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Case 4:07-cv-00473-CEJ

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Of Counsel: Richard S. Mandel, Esq. (admitted pro hac vice) COWAN, LIEBOWITZ & LATMAN, P.C. 1133 Avenue of the Americas New York, New York 10036-6799 [phone] CERTIFICATE OF SERVICE The undersigned hereby certifies that on this 6th day of August 2007, a true and accurate copy of the foregoing was filed electronically with the Clerk of Court to be served by operation of the Court's electronic filing system upon the following persons: Richard S. Mandel, Esq. Cowan, Liebowitz & Latman, P.C. 1133 Avenue of the Americas New York, NY 10036 [phone] email: [e-mail] and via United States Postal Service, as First Class Mail, postage pre-paid to: Mr. Doug Lewis 4143 Fox Crossings St. Louis, MO 63034 /s/ Nicholas B. Clifford, Jr.

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