IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEW JERSEY

CAMDEN VICINAGE

DEREK ABRAJANO,

 Plaintiff,

v.

ACCOUNTS RECEIVABLE

MANAGEMENT, INC.,

 Defendant.

Civil No. 11-3711 (RBK/AMD)

SCHEDULING ORDER

This Scheduling Order confirms the directives given to

counsel at the scheduling conference pursuant to Rule 16, Federal

Rules of Civil Procedure on October 18, 2011; and the Court noting

the following appearances: Brent F. Vullings, Esquire, appearing

on behalf of the plaintiff; and Andrew M. Schwartz, Esquire,

appearing on behalf of the defendant; and for good cause shown:

IT IS this 19th day of October 2011, hereby ORDERED:

1. The Court will conduct a telephone status conference

on December 1, 2011 at 10:00 A.M.. Counsel for plaintiff shall

initiate the telephone call. 

2. The time within which to file a motion to amend the 

pleadings or a motion to join new parties will expire on December

12, 2011.

3. Pretrial factual discovery is hereby extended to

January 31, 2012. All pretrial discovery shall be concluded by

that date. All discovery motions and applications pursuant to L.

CIV. R. 37.1(a)(1) shall be made returnable before the expiration

of pretrial factual discovery.

4. Depositions. All depositions are to be conducted in

accordance with the procedures set forth in the order of Judge

Gawthrop, in Hall v. Clifton Precision, 150 F.R.D. 525 (E.D.Pa.

1993). 

5. All expert reports and expert disclosures pursuant to

FED. R. CIV. P. 26(a)(2) on behalf of plaintiff shall be served upon

counsel for defendant not later than February 29, 2012. All expert

reports and expert disclosures pursuant to FED. R. CIV. P. 26(a)(2)

on behalf of defendant shall be served upon counsel for plaintiff

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not later than March 30, 2012. Each such report should be

accompanied by the curriculum vitae of the proposed expert witness. 

No expert opinion testimony shall be admitted at trial with respect

to any witness for whom this procedure has not been timely

followed. Depositions of proposed expert witnesses shall be

concluded by April 16, 2012.

The parties shall also exchange, in accordance with the

foregoing schedule, written statements identifying all opinion

testimony counsel and the parties anticipate will be presented at

trial pursuant to F. R. EVID. 701 and Teen-Ed v. Kimball

International, Inc., 620 F.2d 399 (3d Cir. 1980).

6. Dispositive Motions. Dispositive motions shall be

filed with the Clerk of the Court no later than March 15, 2012.

Opposition to the motion should be served in a timely fashion. 

Counsel are to follow L. CIV. R. 7.1, 7.2, 56.1 and 78.1 (Motion

Practice - Generally). 

7. Any application for an extension of time beyond the

deadlines set herein shall be made in writing to the undersigned

and served upon all counsel prior to expiration of the period

sought to be extended, and shall disclose in the application all

such extensions previously obtained, the precise reasons

necessitating the application showing good cause under FED. R. CIV.

P. 16(b), and whether adversary counsel agree with the application. 

The schedule set herein will not be extended unless good cause is

shown.

THE FAILURE OF A PARTY OR ATTORNEY TO OBEY THIS ORDER MAY

RESULT IN THE IMPOSITION OF SANCTIONS UNDER FED. R. CIV. P. 16(f).

s/ Ann Marie Donio 

ANN MARIE DONIO

United States Magistrate Judge

cc: Hon. Robert B. Kugler

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