Exhibit A 

Case 1:22-cv-23753-KMM Document 88-1 Entered on FLSD Docket 03/09/2023 Page 1 of 18
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

CASE NO. 1:22-cv-23753-KMM

EDWIN GARRISON, et al., on behalf of 

themselves and all others similarly situated,

Plaintiffs, 

v. 

SAM BANKMAN-FRIED, et al.,

Defendants.

/

JOINT SCHEDULING REPORT

Plaintiffs, Edwin Garrison, et al. (“Plaintiffs”), and Defendants, [PLEASE INSERT 

EACH OF THE DEFENDANTS], (“Defendants”) (Defendants together with Plaintiffs, the 

“Parties”), submit this Joint Scheduling Report pursuant to S.D. Fla. Local Rule 16.1(b), and

Federal Rule of Civil Procedure 26(f)(3). The Parties conferred on March 9, 2023 and Report as

follows:

I. Plaintiffs’ Statement

The FTX disaster is the largest financial fraud in US history. The former FTX CEO, 

Bankman-Fried, is facing numerous criminal charges and the new CEO—who helped wind down 

Enron—concluded that this fraud was much worse than in Enron. Billions of dollars have been 

stolen from investors across the globe. 

FTX was a centralized cryptocurrency platform which specialized in derivatives and 

leveraged products. It filed for bankruptcy protection in November 2022 and will be involved in 

federal bankruptcy proceedings for many years. There is no guarantee that any of the victims will 

Case 1:22-cv-23753-KMM Document 88-1 Entered on FLSD Docket 03/09/2023 Page 2 of 18
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be able to see any recovery from those proceedings.

This is a proposed class action brought on behalf of a Global Class, a Nationwide Class,

and State Subclasses, of all individuals offered or sold, deceptive FTX Yield Bearing Accounts

(“YBAs”), which were admittedly marketed and promoted by the Defendants. Plaintiffs allege—

as the SEC and numerous state securities regulators have already concluded in analogous contexts 

with platforms such as BlockFi,1 Voyager,2 and Celsius,

3 who all offered these same accounts—

that these YBAs are all unregistered “securities” as defined by applicable securities law.

If there was any debate as to how the SEC would rule regarding these specifical allegations, 

they answered that question last week. The SEC recently brought suit, and settled with former 

professional basketball player and sports analyst Paul Pierce (Boston Celtics) for specifically 

touting on Twitter for a two-week period in 2021 a “crypto asset security” that was being offered 

and sold. Although not specific to FTX, the SEC’s findings are extremely instructive about what 

kind of activity violates the securities laws: 

Pierce, at least negligently, made materially false and misleading misstatements in his 

Twitter posts promoting the crypto asset security, including statements regarding the 

amount he had earned from holding the crypto asset security, and statements indicating that 

he was holding—and intended to increase—his investment in the crypto asset security 

while contemporaneously selling the securities. Pierce’s conduct violated Section 17(a)(2) 

of the Securities Act, which prohibits obtaining money or property by means of an untrue 

statement of a material fact or any omission of material facts necessary to make statements 

made not misleading in the offer or sale of securities. 

In addition, Pierce did not disclose that he was being compensated by the entity offering 

1 https://www.sec.gov/news/press-release/2022-26 (accessed March 6, 2023).

2 https://coingeek.com/6-us-regulators-crackdown-on-voyager-digital-over-interest-bearingaccounts/ (accessed March 6, 2023).

3

https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=&cad=rja&uact=8&ved

=2ahUKEwjvjNvg27j7AhWfRTABHfwzDe4QFnoECAsQAQ&url=https%3A%2F%2Fwww.nj.

gov%2Foag%2Fnewsreleases21%2FCelsius-Order9.17.21.pdf&usg=AOvVaw0Zd94fuhFSsOoGKM-vQ3YI (accessed March 6, 2023).

Case 1:22-cv-23753-KMM Document 88-1 Entered on FLSD Docket 03/09/2023 Page 3 of 18
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and selling the security for giving the crypto asset security publicity. Pierce’s failure to disclose 

this compensation violated Section 17(b) of the Securities Act, which makes it unlawful for any 

person to promote a security without fully disclosing the receipt and amount of such consideration 

from an issuer. See In re Pierce, SEC Admin. Proceeding File No. 3-21305 (Feb. 17, 2023) 

(summary of order instituting cease-and-desist proceedings at paras. 1–2).

Defendants’ participation and/or actions in FTX’s offerings and sales of YBAs violated 

various provisions of state securities laws and deceptive trade practices statutes, including those

of Florida, which law may be applied nationwide as Florida is the situs of FTX’s domestic 

headquarters and Florida’s FSIPA and FDUTPA statutes were enacted to regulate the conduct of 

entities based within its borders so that such companies would not utilize the State as a hub for 

their global wrongdoing. Plaintiffs seek certification of a Global Class, a Nationwide Class, and a 

Florida State Subclass under Rule 23(a), (b)(2), (b)(3), and/or (c)(4) of the FRCP, which includes 

seeking a declaration that the YBAs are unlawfully sold unregistered securities, which entitles 

Plaintiffs and class members to full rescissionary damages. Defendants’ substantial participation 

in the offer or sale of these unregistered EPAs, which were offered or sold from the State of Florida 

by FTX, renders Defendants jointly and severally liable to Plaintiffs and all Class Members for the 

full measure of damages resulting from their offer or sale. These specific claims have a strict 

liability standard with no reliance requirements nor any caveat emptor defense. This action may 

be the only avenue for any of the victims to recover any of their admitted damages. 

Plaintiffs’ Counsel have been investigating and litigating these and similar claims against 

failed exchanges FTX and Voyager for two years. After conducting significant research on the 

issues with the top cryptocurrency experts in the field, Plaintiffs’ counsel brought the first 

Case 1:22-cv-23753-KMM Document 88-1 Entered on FLSD Docket 03/09/2023 Page 4 of 18
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nationwide class action against failed cryptocurrency exchange, Voyager Digital,4 where they 

litigated many of these same issues until Voyager declared bankruptcy in July 2022. In August, 

Plaintiffs’ counsel brought the first nationwide class action against some of the largest Brand 

Ambassadors of Voyager for their respective roles in facilitating Voyager’s offer and sale of 

unregistered securities.5 That Voyager litigation is ongoing, and after substantial discovery, 

including reviewing tens of thousands of documents and taking over half a dozen significant 

depositions, Plaintiffs’ counsel have already amassed enough evidence to seek class certification 

and summary judgment on many of the dispositive issues in the case. 

In connection with Voyager’s bankruptcy, Plaintiffs’ counsel closely followed the bidding 

process that culminated in the purported agreement for FTX to purchase Voyager’s customers’ 

assets, where FTX couched themselves as the saviors of Voyager’s customers. Because that 

agreement was founded on many false and fraudulent predicates, however, Plaintiffs’ counsel was 

ready to immediately file this action, the first nationwide class action against FTX, two business 

days after it was revealed that FTX operated as a fraudulent Ponzi scheme and sought emergency 

bankruptcy relief for themselves, leaving both Voyager’s and FTX’s customers blindsided with 

many billions of dollars in losses. Plaintiffs’ counsel have since led the nation’s litigation of these 

issues, bringing a number of nationwide and global class actions, and state court individual actions, 

here in South Florida, where FTX maintained its domestic headquarters and base of operations, in 

order to recover these customers’ losses from any and all responsible parties. 

All of the actions Plaintiffs’ counsel have brought to date have now been consolidated 

and/or transferred to this Honorable Court, where they can be presided over in an organized and 

4 Mark Cassidy v. Voyager Digital Ltd., et al., Case No. 21-24441-CIV-ALTONAGA/Torres 

(the “Cassidy Action”)

5

Robertson, et al. v. Mark Cuban, et al., Case No. 22-CV-22538-ALTMAN/Reid (the “Voyager 

Brand Ambassadors Action”)

Case 1:22-cv-23753-KMM Document 88-1 Entered on FLSD Docket 03/09/2023 Page 5 of 18
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consistent fashion. Given that others around the country are now working to catch up, a rash of 

additional actions against many of these same defendants have been brought around the country. 

As a result, in order to continue to organize these actions and to ensure that they are litigated 

consistently, efficiently, and effectively, Plaintiffs’ counsel filed a petition before the Judicial 

Panel on Multidistrict Litigation, In re: FTX Cryptocurrency Exchange Collapse Litigation, MDL 

No. 3076 (J.P.M.L. 2023) (the “MDL Petition”), seeking to consolidate all pending and yet-to-befiled related actions and to transfer them here to the Southern District of Florida for all pretrial 

purposes. The MDL Petition will be fully briefed by March 17, 2023. This action involves many 

of the very same common legal and factual issues raised by the related actions subject to the MDL 

Petition. 

One such common legal issue, the question of whether the sale of every YBA is (or is not) 

the sale of “unregistered securities,” has practically been answered in the affirmative through 

various regulatory statements, guidance, and actions issued by the Securities and Exchange 

Commission and other regulatory entities. For example, on November 1, 2017, in the “SEC

Statement Urging Caution Around Celebrity Backed ICOs,”6

In the SEC’s Report of Investigation concerning The DAO,7 the Commission warned that 

virtual tokens or coins sold in ICOs may be securities, and those who offer and sell securities in 

the United States must comply with the federal securities laws. Any celebrity or other individual 

who promotes a virtual token or coin that is a security must disclose the nature, scope, and amount 

of compensation received in exchange for the promotion. A failure to disclose this information is 

a violation of the anti-touting provisions of the federal securities laws. Persons making these 

6

https://www.sec.gov/news/public-statement/statement-potentially-unlawful-promotion-icos

(accessed March 6, 2023) (emphasis added).

7 https://www.sec.gov/litigation/investreport/34-81207.pdf (accessed March 6, 2023)

Case 1:22-cv-23753-KMM Document 88-1 Entered on FLSD Docket 03/09/2023 Page 6 of 18
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endorsements may also be liable for potential violations of the anti-fraud provisions of the federal 

securities laws, for participating in an unregistered offer and sale of securities, and for acting 

as unregistered brokers. The SEC will continue to focus on these types of promotions to protect 

investors and to ensure compliance with the securities laws.

Now that nearly all Defendants are properly before this Court, discovery will proceed 

expeditiously and efficiently. Plaintiffs will then move for certification of an issue class pursuant 

to Federal Rules of Civil Procedure 23(a), (b)(3), and (c)(4), with respect to the very specific, 

narrow and simple issue of whether (or not) the YBAs constitute unregistered securities. Plaintiffs 

are seeking to have this simple issue determined by the Court as soon as practicable. Plaintiffs will 

thereafter seek a determination on this issue, either through summary judgment or an expedited 

trial to the extent the Court deems the determination to be an issue of fact. 

II. Defendants’ Statement

[INSERT DEFENDANTS’ STATEMENT(S)].

Defendant Sam Bankman-Fried is a defendant in a criminal matter set for trial in October, 

2023 n United States v. Bankman-Fried, 22-cr-00673 (LAK) (S.D.N.Y.). The issues in the present 

action are inextricably intertwined with the subject of the criminal matter. In order to protect his 

Constitutional rights pursuant to the Fifth Amendment, Mr. Bankman-Fried respectfully submits 

that the claims against him should be severed from the present action, and that all aspects of the 

present action, including discovery, should be stayed as against him pending the outcome of the 

criminal matter.

Case 1:22-cv-23753-KMM Document 88-1 Entered on FLSD Docket 03/09/2023 Page 7 of 18
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III. Conference Report – Information Required by L.R. 16.1(B)(2)

A. Likelihood of Settlement

Plaintiffs believe that that any discussion of settlement would be premature at this stage. 

Defendants believe that [INSERT DEFENDANTS’ STATEMENT(S)]. Defendant Sam 

Bankman-Fried incorporates his statement in response to item II above. Nonetheless, the 

Parties agree to comply with any requirements under the Local Rules with respect to good faith 

settlement discussions.

B. Likelihood of Appearance in the Action of Additional Parties

Plaintiffs believe that, as discovery progresses, additional parties may be added. [INSERT 

DEFENDANTS’ STATEMENT(S)] Defendant Sam Bankman-Fried incorporates his statement in 

response to item II above

C. Proposed Limits on Time

See the proposed case schedule at Section V, below.

D. Proposals for the Formulation and Simplification of Issues

Plaintiffs submit that the Parties will work in good faith to simplify the issues at an 

appropriate time. Defendants submit that, [INSERT DEFENDANTS’ STATEMENT(S)].

Defendant Sam Bankman-Fried incorporates his statement in response to item II above

Case 1:22-cv-23753-KMM Document 88-1 Entered on FLSD Docket 03/09/2023 Page 8 of 18
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E. Necessity or Desirability of Amendments to the Pleadings

Although the Parties do not anticipate a need to amend the pleadings at this time, Plaintiffs 

have proposed a deadline for amendments in their proposed schedule for after the Court’s decision 

on class certification, in the event Plaintiffs need to convert this action to a mass action.

Defendants believe that, [INSERT DEFENDANTS’ STATEMENT(S)]. Defendant Sam 

Bankman-Fried incorporates his statement in response to item II above

F. Possibility of Obtaining Admissions and Stipulations

Plaintiffs will cooperate in good faith to obtain admissions and stipulations in the discovery 

process that will limit the issues in dispute and reduce the time needed to conduct a trial. 

Defendants [INSERT DEFENDANTS’ STATEMENT(S)]. Defendant Sam Bankman-Fried 

incorporates his statement in response to item II above

G. Suggestions for the Avoidance of Unnecessary Proof and of Cumulative 

Evidence

Plaintiffs have no suggestions at this time but will cooperate in good faith to eliminate 

unnecessary proof and cumulative evidence. 

Defendants submit that [INSERT DEFENDANTS’ STATEMENT(S)]. Defendant Sam 

Bankman-Fried incorporates his statement in response to item II above

H. The Advisability of Referring of Matters to a Magistrate Judge

Plaintiffs consent to refer discovery motions to a Magistrate Judge. Defendants submit

that [INSERT DEFENDANTS’ STATEMENT(S)]. Defendant Sam Bankman-Fried 

incorporates his statement in response to item II above

The Parties do not consent to trial by a Magistrate Judge, nor to the disposition of

dispositive pre-trial motions by a Magistrate Judge.

I. Preliminary Estimate of Time Required for Trial

Case 1:22-cv-23753-KMM Document 88-1 Entered on FLSD Docket 03/09/2023 Page 9 of 18
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Plaintiffs estimate that a trial in this matter would require 5–7 days. Plaintiffs demand a 

jury trial.

Defendants estimate a trial in this matter would likely require [INSERT Defendant Sam 

Bankman-Fried incorporates his statement in response to item II above DEFENDANTS’ 

STATEMENT(S)].

J. Pretrial Conference and Trial Dates

See Section V, below.

K. Any Discovery Issues

Plaintiffs will cooperate in good faith to develop protocols to facilitate electronic 

discovery and govern privilege issues without the involvement of the Court. This may include 

the submission of an agreed confidentiality order.

Defendants submit that [INSERT DEFENDANTS’ STATEMENT(S)]. Defendant Sam 

Bankman-Fried incorporates his statement in response to item II above

IV. Additional Information Required by L.R. 16(B)(3)

A. Assignment of the Case to a Particular Track

Plaintiffs’ position is that this case merits a standard case management track at this stage, 

as defined by Local Rule 16.1, and as set forth in their schedule proposed in section V, below.

The claims in this lawsuit center on whether FTX’s applicable offerings constitute securities 

that were required to be registered under applicable securities laws, a determination that lends 

itself to issue class certification pursuant to Federal Rule of Civil Procedure 23(c)(4). Thereafter, 

this matter can proceed to an expedited trial on those issues which would efficiently and 

expediently determine whether Defendants may be found liable under these claims. 

Defendants believe that, [INSERT DEFENDANTS’ STATEMENT(S)]. Defendant Sam 

Case 1:22-cv-23753-KMM Document 88-1 Entered on FLSD Docket 03/09/2023 Page 10 of 18
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Bankman-Fried incorporates his statement in response to item II above

B. Detailed Discovery Schedule

Plaintiffs’ scheduling proposal for discovery is set forth below, at Section V.

[INSERT DEFENDANTS’ STATEMENT(S)] Defendant Sam Bankman-Fried 

incorporates his statement in response to item II above

C. Any Agreements or Issues Regarding Discovery

There are currently no agreements or issues to be decided by the Court regarding the 

preservation, disclosure, and discovery of documents, electronically stored information, or other 

tangible things. The Parties will cooperate in good faith to develop protocols to facilitate 

electronic discovery and govern privilege and confidentiality issueswithout the involvement of 

the Court. 

V. The Parties’ Proposed Schedule

Plaintiffs propose the following schedule:

Date Deadline or Event

March 24, 2023 Deadline to furnish Initial Disclosures pursuant to FRCP 26

April 14, 2023 Deadline for Defendants to respond to the Amended Complaint

April 14, 2023 Deadline to select mediator, and schedule time, date and place

June 2, 2023 Deadline for Plaintiffs to file Motion for Class Certification

Within 40 days following the 

filing of Plaintiffs’ motion

Deadline for Defendants to file response to Plaintiffs’ Motion 

for Class Certification

Within 20 days following the 

filing of Defendants’ response Deadline for Plaintiffs to file Reply in support of Plaintiff’s 

Motion for Class Certification

To be set by the Court. Hearing on Plaintiff’s Motion for Class Certification

Within 21 days following the 

Court’s ruling on Plaintiff’s 

motion for class certification Deadline to file motions to amend pleadings or join parties

Case 1:22-cv-23753-KMM Document 88-1 Entered on FLSD Docket 03/09/2023 Page 11 of 18
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September 29, 2023 Deadline to complete fact discovery

October 13, 2023 Deadline for Parties to disclose experts, expert witness 

summaries and reports

November 3, 2023 Deadline to complete mediation

Within 28 days of each Party’s 

expert disclosures Deadline to exchange rebuttal expert witness summaries and 

reports

Within 21 days of each 

Party’s rebuttal expert 

disclosures Deadline to complete expert discovery

January 5, 2024 Deadline to file all dispositive pre-trial motions

February 2, 2024 Deadline to respond to all dispositive pre-trial motions

February 16, 2024 Deadline to reply in support of all dispositive pre-trial motions

March 1, 2024 Deadline to file joint pretrial stipulation, witness lists, exhibit

lists, accordance with Local Rule 16.1(d) and (e), and proposed 

jury instructions/conclusions of law (for non-jury trials)

March 15, 2024 Deadline for Parties to submit their deposition designations

March 29, 2024 Deadline to file Daubert motions, motions to strike experts

April 8, 2024 (approximate)

Two-week trial period commences

[INSERT DEFENDANTS’ STATEMENT(S)/PROPOSED SCHEDULE(S)] Defendant 

Sam Bankman-Fried incorporates his statement in response to item II above

VI. Federal Rule of Civil Procedure 26(F)(3) Discovery Plan

A. What changes should be made in the timing, form, or requirement

for disclosures under Rule 26(a), including a statement of when 

initial disclosures were made or will be made.

Plaintiffs propose that the Parties serve Initial Disclosures on March 24, 2023, and 

Case 1:22-cv-23753-KMM Document 88-1 Entered on FLSD Docket 03/09/2023 Page 12 of 18
12

supplement their Disclosures, if necessary, in accordance with F.R.C.P. 26(a).

[INSERT DEFENDANTS’ STATEMENT(S)] Defendant Sam Bankman-Fried 

incorporates his statement in response to item II above

B. The subjects on which discovery may be needed, when discovery should

be completed, and whether discovery should be conducted in phases or 

be limited to or focused on particular issues.

Plaintiffs’ discovery will be centered on Defendants’ practices, agreements, and 

representations concerning FTX’s Yield-Bearing Accounts (“YBAs”) and FTX’s native 

cryptocurrency token, FTT, as marketed and promoted by the Defendants. Plaintiffs submit that 

discovery should not be phased or otherwise limited to any particular issues.

[INSERT DEFENDANTS’ STATEMENT(S)]. Defendant Sam Bankman-Fried 

incorporates his statement in response to item II above

C. Any issues about disclosure, discovery, or preservation of electronically

stored information, including the form or forms in which it should be

produced

Plaintiffs will work in good faith to resolve issues concerning discovery and the production 

of electronically stored information. Defendants submit that [INSERT DEFENDANTS’ 

STATEMENT(S)]. Defendant Sam Bankman-Fried incorporates his statement in response to item 

II above The Parties will use their best efforts to resolve discovery disputes without the need for 

unnecessary motion practice before the Court, but respectfully reserve their rights to seek 

assistance from the Court if needed.

D. Any issues about claims of privilege or of protection as trial-preparation 

materials, including—if the parties agree on a procedure to assert these

claims after production— whether to ask the court to include their 

agreement in an order under Federal Rule of Evidence 502

Plaintiffs agree to use the proceduresset forth in Fed. R. Civ. P. 26(b)(5), Fed. R. Evid. 502,

and any protective order entered in this action regarding any claims of privilege or protection for

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materials asserted as prepared in anticipation of litigation or trial.

[INSERT DEFENDANTS’ STATEMENT(S)]. Defendant Sam Bankman-Fried 

incorporates his statement in response to item II above

E. What changes should be made in the limitations on discovery imposed 

under these rules or by local rule, and what other limitations should be

imposed

At this time, the Parties do not propose any additional limitations on discovery besides 

what has already been addressed herein.

F. Any other orders that the court should issue under Rule 26(c) or under Rule 

16(b) and (c)

At this time, the Parties do not propose any changes to the limitations imposed under 

the Federal Rules of Civil Procedure.

Dated: March 10, 2023

By: /s/ DRAFT

Adam M. Moskowitz

Florida Bar No. 984280

adam@moskowitz-law.com 

Joseph M. Kaye

Florida Bar No. 117520

joseph@moskowitz-law.com

THE MOSKOWITZ LAW FIRM, PLLC

2 Alhambra Plaza, Suite 601

Coral Gables, FL 33134 

Telephone: (305) 740-1423

By: /s/ DRAFT

David Boies

(Admitted Pro Hac Vice)

Alexander Boies

(Admitted Pro Hac Vice)

BOIES SCHILLER FLEXNER LLP

333 Main Street

Armonk, NY 10504

Phone: (914) 749–8200

dboies@bsfllp.com

By: /s/ DRAFT

[INSERT DEFENDANTS’ COUNSEL]

Counsel for Defendants

Case 1:22-cv-23753-KMM Document 88-1 Entered on FLSD Docket 03/09/2023 Page 14 of 18
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By: /s/ DRAFT

Stephen Neal Zack

Florida Bar No. 145215

BOIES SCHILLER FLEXNER LLP

100 SE 2nd St., Suite 2800

Miami, FL 33131

Office: 305-539-8400

szack@bsfllp.com

Co-Counsel for Plaintiffs and the Class

Case 1:22-cv-23753-KMM Document 88-1 Entered on FLSD Docket 03/09/2023 Page 15 of 18
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CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the forgoing was filed on March 10, 2023, 

with the Court via the CM/ECF system, which will send notification of such filing to all 

attorneys and/or parties of record, as well as via U.S. Mail and/or equivalent courier service to 

any parties who have been served but who have not yet entered appearances in this action.

By: s/ DRAFT

 ADAM M. MOSKOWITZ

Case 1:22-cv-23753-KMM Document 88-1 Entered on FLSD Docket 03/09/2023 Page 16 of 18
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

CASE NO. 1:22-cv-23753-KMM

EDWIN GARRISON, et al., on behalf of 

themselves and all others similarly situated,

Plaintiffs, 

v. 

SAM BANKMAN-FRIED, et al.,

Defendants.

/

[PROPOSED] SCHEDULING ORDER 

Having considered the Joint Conference Report of the parties [ECF No. __], the Court 

hereby ORDERS the following: 

I. PRETRIAL DEADLINES

Date Deadline or Event

March 24, 2023 Deadline to furnish Initial Disclosures pursuant to FRCP 26

April 14, 2023 Deadline for Defendants to respond to the Amended Complaint

April 14, 2023 Deadline to select mediator, and schedule time, date and place

June 2, 2023 Deadline for Plaintiffs to file Motion for Class Certification

Within 40 days following 

the filing of Plaintiffs’

motion

Deadline for Defendants to file response to Plaintiffs’ Motion 

for Class Certification

Within 20 days following 

the filing of Defendants’ 

response

Deadline for Plaintiffs to file Reply in support of Plaintiff’s 

Motion for Class Certification

To be set by the Court. Hearing on Plaintiff’s Motion for Class Certification

Within 21 days following 

the Court’s ruling on Deadline to file motions to amend pleadings or join parties

Case 1:22-cv-23753-KMM Document 88-1 Entered on FLSD Docket 03/09/2023 Page 17 of 18
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Plaintiff’s motion for class 

certification

September 29, 2023 Deadline to complete fact discovery

October 13, 2023 Deadline for Parties to disclose experts, expert witness 

summaries and reports

November 3, 2023 Deadline to complete mediation

Within 28 days of each 

Party’s expert disclosures Deadline to exchange rebuttal expert witness summaries and 

reports

Within 21 days of each 

Party’s rebuttal expert 

disclosures Deadline to complete expert discovery

January 5, 2024

Deadline to file all dispositive pre-trial motions

February 2, 2024 Deadline to respond to all dispositive pre-trial motions

DONE AND ORDERED in Miami, Florida this __ day of _____, 2023.

_________________________________

HONORABLE K. MICHAEL MOORE

UNITED STATES DISTRICT JUDGE

Copies furnished to: 

Counsel of record

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