[brief] It is uncontested that when the discovery period ended on November 17, 2022, plaintiff had not served the report of any expert witness who opined that [...] deviated from applicable standards of care, or that such alleged deviations proximately caused [...]’s claimed injuries.  It is similarly uncontested that plaintiff did not seek to extend discovery either before the discovery end date, or before the Law Division assigned a trial date.  Plaintiff’s first request to reopen and extend discovery was made after the discovery end date; after a trial date was assigned; and after defendants, including [...], moved to dismiss plaintiff’s claims on grounds that plaintiff had never served the reports of any expert witnesses, and thus could not set forth a prima facie case against any defendant.  Finally, it is uncontested that plaintiff’s failure to seek a discovery extension was an admitted oversight by plaintiff’s attorney.  (Pb18, Pb31.)  On behalf of [...], we respectfully submit that the Law Division’s decisions denying plaintiff’s January 11, 2023, motion to reopen and extend discovery, and granting [...]’s motion to dismiss, were properly granted.  Plaintiff failed to set forth the existence of any “exceptional circumstances” to justify a discovery extension, as our Court Rules mandate once the discovery end date has passed and a trial date has been set.  Moreover, plaintiff only sought an extension so that she could serve a report from an expert witness, [...], who is not qualified to opine that [...] deviated from the standard of care.  Therefore, even if the Law Division had granted an extension so that plaintiff could serve [...]’s report, she still could not set forth a *prima facie* case against [...].  Dismissal of the claims against [...] remained the appropriate outcome.  Plaintiff has *never* explained, either to the court below, or in her current appeal, why she did not serve the report of an expert qualified to offer opinions regarding [...].  The Law Division’s subsequent order, denying the plaintiff’s motion for reconsideration, was an appropriate exercise of discretion.  As noted by the court below, the only explanation that plaintiff had provided for not serving expert reports was [...]’s ongoing medical problems.  But these would not logically affect any expert witness’ ability to draft a report, or her attorney’s ability to request an extension of discovery in a timely fashion.  The denial of the plaintiff’s subsequent “motion to vacate” pursuant Rule 4:50-1, essentially a second motion for reconsideration, was another appropriate exercise of the Law Division’s discretion.  Plaintiff’s motion merely repeated her prior arguments under the guise of a different court rule and failed to demonstrate the existence of “truly exceptional circumstances” that would warrant any relief under that rule.  The vague references by plaintiff’s attorney to “staffing shortages,” and his own admitted oversight (19a at ¶ 12; 22a-24a), did not amount to “exceptional circumstances,” as that term is understood by our courts.  Therefore, for the reasons set forth herein, defendant [...] respectfully submits that all of the Law Division’s rulings should be affirmed.