EXHIBIT A

Redlined Version of the Court’s Preliminary Proposed Deadlines

Case:17-03283-LTS Doc#:23636-1 Filed:02/27/23 Entered:02/27/23 13:33:29 Desc:

Exhibit A Redlined Version of the Courts Preliminary Proposed Deadlines Page 1 of 5
Summary of Discovery Deadlines3

Date of Entry of 

This Order Conversion of Disclosure Statement depository to Plan Depository 

Five Business Days 

After Entry of DS 

Approval Order 

Deadline for Confirmation Hearing Notice to be served. 

Ten Days After 

Entry of This Order

Deadline for the Debtor to upload all documents to the Plan Depository 

Deadline for the Debtor to file a preliminary fact witness list and topics 

about which each witness will testify (“Debtor’s Preliminary Fact 

Witness List”). 

March 29April 7, 

2023 

Deadline for parties in interest to file a “Notice of Intent to Participate in 

Discovery,” (hereafter, a “Discovery Notice”). Only parties in interest 

who file a timely Discovery Notice can propound discovery, but failure 

to do so does not preclude a party from objecting to confirmation of the 

Plan. 

28 Days After Entry 

of DS Approval 

Order

Deadline for Debtor to complete mailing of solicitation materials.

April 143, 2023

Deadline for all parties to serve requests for production of nondepository documents (“Production Requests”). Parties in interest may 

serve Production Requests only following their filing of a timely 

Discovery Notice. 

Parties may serve up to one additional round of Production Requests, 

provided that they are served on or before April 14May 8, 2023. 

Responses and objections to any Production Requests shall be served 

within seven (7) days of service of such Production Requests.

Deadline for parties in interest to file a preliminary fact witness list and 

topics about which each witness is expected to testify (a “Party in 

Interest’s Preliminary Fact Witness List,” and together with the 

Debtor’s Preliminary Fact Witness List, the “Preliminary Fact Witness 

Lists”). 

Deadline for all parties to file opening expert disclosures (“Opening 

Expert Disclosures”). 

3

 The confirmation deadlines approved in connection with the Disclosure Statement Motion are highlighted below 

in grey shading. 

Case:17-03283-LTS Doc#:23636-1 Filed:02/27/23 Entered:02/27/23 13:33:29 Desc:

Exhibit A Redlined Version of the Courts Preliminary Proposed Deadlines Page 2 of 5
Summary of Discovery Deadlines3

April 21, 2023 

Deadline for all parties to serve up to fifteen (15) interrogatories 

(“Interrogatories”), including subparts. Responses and objections to 

such Interrogatories shall be served within ten (10) days of service of 

such Interrogatories.

April 2814, 2023

Deadline for all parties to file opening expert reports (“Opening Expert 

Reports”). 

Deadline for all parties to serve initial notices of deposition, topics and 

requested times for depositions (“Initial Notices of Deposition”) (all 

depositions are limited to a seven (7)-hour time limit). Subsequent 

notices are allowed provided discovery is completed by the Fact 

Discovery Deadline or Expert Discovery Deadline, as applicable. 

Deadline for parties who have served a Production Request on or 

before April 3, 2023 to serve up to one additional round of Production 

Requests. 

Responses and objections to any Production Requests shall be served 

within seven (7) days of service of such Production Requests.

Deadline for all parties to serve initial notices of deposition, topics and 

requested times for depositions (“Initial Notices of Deposition”) (all 

depositions are limited to a seven (7)-hour time limit). Subsequent 

notices are allowed provided discovery is completed by the Fact 

Discovery Deadline or Expert Discovery Deadline, as applicable. 

April 17May 8, 

2023 

Deadline for all parties to file rebuttal expert disclosures (“Rebuttal 

Expert Witness Disclosures”)

Deadline for parties who have served a Production Request on or 

before April 14, 2023 to serve up to one additional round of Production 

Requests. 

Responses and objections to any Production Requests shall be served 

within seven (7) days of service of such Production Requests.

May 15, 2023 Deadline for all parties to file rebuttal expert reports (“Rebuttal Expert 

Reports”) 

April 21May 26, 

2023 

Deadline for all parties to serve requests for admission, limited to 

authentication of documents (“Admission Requests”). Responses and 

objections to such Admission Requests shall be served within four (4) 

business days of service of such Admission Requests. 

Deadline for completion of fact discovery (the “Fact Discovery 

Deadline”). 

Deadline for parties in interest who solely want access to documents in 

the Plan Depository to file a Discovery Notice.

Case:17-03283-LTS Doc#:23636-1 Filed:02/27/23 Entered:02/27/23 13:33:29 Desc:

Exhibit A Redlined Version of the Courts Preliminary Proposed Deadlines Page 3 of 5
Summary of Discovery Deadlines3

June 2, 2023

April 24, 2023

Deadline for completion of expert discovery (the “Expert Discovery 

Deadline”).

Deadline for all parties to file Daubert motions and motions in 

limine.Deadline for all parties to file rebuttal expert reports (“Rebuttal 

Expert Reports”) 

Deadline for parties in interest who solely want access to documents in 

the Plan Depository to file a Discovery Notice.

June 9, 2023May 5, 

2023

Deadline for all parties to file oppositions to Daubert motions and 

motions in limine.

June 16, 2023

Deadline for all parties to file replies in support of Daubert motions and 

motions in limine.

Deadline for all parties to file finalized witness lists, exhibit lists, and 

deposition designations.

May 17June 23, 

2023 

Deadline for all parties to file counter-designations, objections to 

deposition designations, or objections to exhibit lists. 

May 24June 30, 

2023 Deadline for all parties to file objections to counter designations. 

May 31, 2023 Deadline for the Debtor to file initial proposed confirmation order (the 

“Proposed Confirmation Order”). 

June 7, 2023 Voting Deadline 

June 7, 2023 

Deadline for parties in interest to file: 

x Objections to confirmation of the Plan (“Plan Objections”). 

x Objections to Proposed Confirmation Order. 

June 21, 2023 

Deadline for Debtor to file: 

x Memorandum of law in support of confirmation. 

x Omnibus reply to Plan Objections and objections to the Proposed 

Confirmation Order 

x Vote Tabulation. 

x Initial proposed findings of fact and conclusions of law 

(“Proposed Findings of Fact and Conclusions of Law”) 

x Witness declarations. 

Deadline for non-Debtor parties to file witness declarations 

Case:17-03283-LTS Doc#:23636-1 Filed:02/27/23 Entered:02/27/23 13:33:29 Desc:

Exhibit A Redlined Version of the Courts Preliminary Proposed Deadlines Page 4 of 5
Summary of Discovery Deadlines3

June 28, 2023 Deadline for parties in interest to file objections to Proposed Findings of 

Fact and Conclusions of Law.

July 5, 2023 Deadline for Debtor to reply to objections to the Proposed Findings of 

Fact and Conclusions of Law. 

Week of July 10, 

2023 

(or a date 

convenient for the 

court)

[Virtual] hearing on motions in limine / pre-trial conference.

July 17–21, 24–28 

2023 Confirmation Hearing

Case:17-03283-LTS Doc#:23636-1 Filed:02/27/23 Entered:02/27/23 13:33:29 Desc:

Exhibit A Redlined Version of the Courts Preliminary Proposed Deadlines Page 5 of 5