UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

MARY ANN SIVOLELLA, : Civil Action No. 11-4194 (PGS) 

:

Plaintiff, :

:

v. : PRETRIAL SCHEDULING ORDER

:

AXA EQUITABLE LIFE INSURANCE : 

COMPANY, et al., :

:

Defendants. :

_________________________________________ :

 

This matter having come before the Court during an initial scheduling 

conference on November 13, 2012; pursuant to FED. R. CIV. P. 16; and the Court having

conferred with counsel concerning the timely completion of discovery; and good cause

appearing for the entry of the within Order;

IT IS on this 16 day of November 2012, th

ORDERED THAT:

1. In accordance with FED. R. CIV. P. 26 (a)(1), each party will submit a

letter, not later than December 14, 2012, to the undersigned certifying that initial

disclosures have been made. This material will not be filed with the Clerk of the Court.

2. No later than December 14, 2012, each party shall designate a

representative knowledgeable about their respective electronic information systems.

3. The Parties’ written discovery requests must be served by December 24,

2012. Additional discovery requests may be served at any time prior to sixty (60) days in

advance of the close of discovery.

4. The Parties will complete fact discovery, including depositions, in this

case by March 5, 2014.

5. Initially the Parties shall be limited to 15 depositions per side. Additional

depositions may be taken with leave of the Court. In accordance with FED. R. CIV. P. 33,

the Parties will be limited to 25 interrogatories (including all subparts), per party, except

upon leave of the Court.

6. Any motion to amend the pleadings or join new parties whether by

amended or third-party complaint must be filed by March 1, 2013.

7. Counsel must meet and confer in an attempt to resolve any discovery or case

management disputes before making such dispute the subject of a motion. No discovery

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motion will be entertained absent counsel's full compliance with L. CIV. R. 37.1(a)(1); see also

L. CIV. R. 16.1(f). Any unresolved disputes must be brought to the Court’s attention

immediately.

8. Plaintiffs shall serve copies of any affirmative expert disclosures and reports

by May 6, 2014.

9. Defendants shall serve copies of any rebuttal expert disclosures and reports

by July 7, 2014.

10. Expert depositions are to be completed by September 5, 2014.

11. No expert shall testify at the time of trial as to any opinions, nor base those

opinions on facts, not substantially disclosed in any report as described in the preceding

paragraphs.

12. The Court will conduct telephone status conferences on January 30, 2013

at 10:00 A.M., April 29, 2013 at 10:30 A.M., August 1, 2013 at 2:00 P.M., December 2, 2013

at 10:30 A.M., and February 3, 2014 at 10:30 A.M. Defendants’ counsel will initiate these

calls.

13. The Court may, from time to time, schedule conferences as may be

required, either on its own motion or at the request of counsel. Failure to appear at

subsequent conferences, or to comply with any of the terms of this Order, may result in

sanctions.

14. Since all dates set forth herein are established with the assistance and

knowledge of counsel, there will be no extensions except for good cause shown and by leave

of Court, even with consent of all counsel.

15. Counsel are invited to use the George H. Barlow Attorney Conference Room

located on the third floor of the Courthouse Annex. The room is equipped with telephones,

laptop access/printer, copier, and fax.

s/ Douglas E. Arpert 

DOUGLAS E. ARPERT

United States Magistrate Judge

ALL PROPOSED ORDERS AND LETTER MEMORANDA SENT TO CHAMBERS

SHOULD BE IN WORDPERFECT FORMAT AND E-MAILED TO:

dea_orders@njd.uscourts.gov. ANY FILINGS WITH THE CLERK’S OFFICE SHOULD BE

IN PDF FORMAT.

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