RE: Discovery14 Aug 2019 20:15
its all gone off tsbs! we've pretty much won !! ZAZA FOR WORLD PRESIDENT WHOOP WHOOP!!!!!
ODR Earlier, this is the California discovery, not long now early 2020 will be here soon, I cant wait :'(
JOINT CASE MANAGEMENT STATEMENT & [PROPOSED] ORDER
4810-5805-3789v.4
The scope of anticipated discovery will extend to the matters alleged in the
First Amended Verified Complaint and related defenses, as well as affirmative
defenses, asserted in Defendants’ Answer, and any matter reasonably related
thereto or reasonably calculated to lead to the discovery of admissible evidence.
The parties have not proposed limitations or modifications of the discovery
rules.
The parties have discussed and considered entering into a stipulated ediscovery order, but at this point in time have not agreed on the terms of such a
potential order.
The proposed discovery plan pursuant to Fed. R. Civ. P. 26(f) is as follows:
(a) following initial disclosures, the parties will mutually engage in written and
document discovery; (b) following initial exchanges of documents the parties will
meet and confer to determine what, if any, e-discovery may be required; (c) upon
completion of written, document, and e-discovery, the parties will conduct
depositions, commencing in early 2020; (d) fact discovery will cut-off on March
31, 2020; (e) expert discovery to be completed by May 15, 2020.
There are no identified discovery disputes at present.
