Equal Employment Opportunity Commission v. Kelley Drye & Warren, LLP

Filing 96

ENDORSED LETTER addressed to Magistrate Judge Michael H. Dolinger from Bettina B. Plevan dated 10/27/2011 re: On October 19, 2011, Your Honor granted the parties joint request' for a two month extension of fact discovery. In the parties' joint request we stated that we would provide a proposed schedule for the completion of expert discovery and dispositive motions. We have consulted with the EEOC and our proposed schedule follows: January 16, 2012: Initial expert designation February 15,1012: Expert counter designation March 2, 2012: Expert report from experts designated initially on January 16 April 2, 2012: Expert reports due for experts counter designated on February 15 April 16, 2012: Expert reports in reply to reports served on March 2, 2012 April 2 April 30, 2012: Comp1etion of expert depositions May 25, 2012: Deadline for dispositive motion (this deadline would be moved to April 27 if no experts are designated. ENDORSEMENT: The proposed amendments to the current pretrial schedule are adopted., ( Deposition due by 4/30/2012., Motions due by 4/27/2011.) (Signed by Magistrate Judge Michael H. Dolinger on 10/27/2011) (js)

10/27/2011 THU

15~26

FAX

!;iID002/002

Bettina

October 27, 2011

d 212.969.3065
f212.969.2900

By Fax and Mail

[e-mail]
\WNJ.proakauer,c;om

Chief Magistrate Judge Michael H. Dolinger
United States District Court
Southern District of New York
United States Courthouse
SOO Pearl Street
New York. New York 10007
Re:

a, Plevan

Member of the Firm

EEOC v. Kelley Drye & Warren LLP
Case No. 10CY 655 (MHO)

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Dear Judge Dolinger:
On October 19.2011, Your Honor granted the parties joint request' for a two month extension of
fact discovery. In the parties' joint request we stated that we would provide a proposed schedule
for the completion of expert discovery and dispositive motions. We have consulted with the
EEOC and our proposed schedule follows:

January 16,2012:
February 15,1012:
March 2, 2012:
April 2, 2012:
April 16, 2012:
April 30, 2012:
May 25,2012:

Initial expert designation
Expert counter designation
Expert report from experts designated initially on January 16
Expert reports due for experts cOWlter designated on February 15
Expert reports in reply to reports served on March 2 01' April 2
Comp1etion of expert depositions
Deadline for dispositive motion (this deadline would be moved to April
27 if no experts are designated)

Thank you for Your Honor~s consideration of this matter.

cc:

Jeffrey Burstein, Esq.

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FAX Cover Sheet

Date: October 27,2011
To:
Elizabeth Anne Grossman, Esq.
Fax: [phone]
Jeffrey Charles Burstein, Esq.

Fax: [phone]

Bettina Barasch Plevan, Esq.

Fax: [phone]

Joseph C. O'Keefe, Jr, Esq.

Proskauer Rose LLP

Fax: [phone]

Re:

EEOC v. Kelley Drye & Warren, LLP.
10 Civ. 655 (LTS) (MHO)
Endorsed order: "The proposed amendments to the current pretrial
schedule are adopted. 11

From:

Magistrate Judge Michael H. Dolinger
United States District Court
Southern District of New York
500 Pearl Street, Room 1670
New York, New York 10007-1312
FAX [phone]
TELEPHONE NUMBER [phone]

This document contains

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pages, including this cover sheet.