Exhibit B

FOMB Demonstrative No. 1

Case:17-03283-LTS Doc#:23594-2 Filed:02/21/23 Entered:02/21/23 16:18:04 Desc:

Exhibit B Page 1 of 5
FOMB Demonstrative No. 1

Case:17-03283-LTS Doc#:23594-2 Filed:02/21/23 Entered:02/21/23 16:18:04 Desc:

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Summary of Discovery Deadlines1

Date of Entry of 

Confirmation/Discovery 

Procedures 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 

Confirmation/Discovery 

Procedures 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 29, 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 3, 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 14, 

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”). 

1 The proposed confirmation deadlines in the Disclosure Statement Motion are highlighted below in grey shading.

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Summary of Discovery Deadlines1

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 14, 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.

April 17, 2023 Deadline for all parties to file rebuttal expert disclosures (“Rebuttal 

Expert Witness Disclosures”)

April 21, 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”). 

April 24, 2023

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.

April 28, 2023

Deadline for all parties to file Daubert motions and motions in 

limine.

Deadline for completion of expert discovery (the “Expert Discovery 

Deadline”).

May 5, 2023 Deadline for all parties to file oppositions to Daubert motions and 

motions in limine.

May 12, 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 17, 2023 Deadline for all parties to file counter-designations, objections to 

deposition designations, or objections to exhibit lists. 

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Summary of Discovery Deadlines1

May 24, 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 & Election Deadline

June 7, 2023

Deadline for parties in interest to file:

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

• Objections to Proposed Confirmation Order.

June 21, 2023

Deadline for Debtor to file:

• Memorandum of law in support of confirmation.

• Omnibus reply to Plan Objections and objections to the 

Proposed Confirmation Order

• Vote Tabulation.

• Initial proposed findings of fact and conclusions of law 

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

• Witness declarations.

Deadline for non-Debtor parties to file witness declarations

June 28, 2023

Deadline for parties in interest to file objections to the (i) Vote 

Tabulation and/or (ii) Proposed Findings of Fact and Conclusions 

of Law.

July 5, 2023

Deadline for Debtor to reply to objections to the (i) the Vote 

Tabulation and (ii) 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#:23594-2 Filed:02/21/23 Entered:02/21/23 16:18:04 Desc:

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