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DISCOVERY TIMELINE

3. Discovery. Unless otherwise ordered by the Court or agreed to by parties, the limitations on discovery set forth in the Federal Rules of Civil Procedure shall be strictly observed.

(a) Fact Discovery Cut Off. All fact discovery in this case shall be initiated so that it will be completed on or before December 23, 2022.

(b) Cross-Use of Discovery. The parties hereby agree that any discovery taken
in the arbitration referenced in the complaint shall be deemed to have been taken in this action, and Defendants shall expeditiously provide Plaintiff with copies of any discovery requests, written discovery responses, documents, and deposition transcripts exchanged or taken in the arbitration.

( c) Document Production. Document production shall be substantially complete by November 28, 2022.
___________________________________

Nov 29, 2022

Main Doc­ument

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE
Plaintiff
C.A. No. l:21-cv-01456-GBW
CHANBOND, LLC,
Defendant
and
DIERDRE LEANE and IPNA V, LLC,
Defendants.

 SCHEDULING ORDER
This ___ day of A} We~~ , 2022, in lieu of the conducting an initial Rule
16(b) scheduling conference pursuant to Local Rule 16.l(b), and the parties having determined after discussion that the matter cannot be resolved at this juncture by settlement, voluntary mediation, or binding arbitration;

IT IS ORDERED that:
1. Rule 26{a)(l) Initial Disclosures and E-Discovery Default Standard. Unless
otherwise agreed to by the parties, the parties shall make their initial disclosures pursuant to Federal Rule of Civil Procedure 26(a)(l) within five (5) days of the date the Court entered this Order if they have not done so already. If they have not already done so, the parties are to review the Court's Default Standard for Discovery, Including Discovery of Electronically Stored Information ("ESI"), which is posted at http://www.ded.uscourts.gov (see Other Resources, Default Standard for Discovery) and is incorporated herein by reference.
Case 1:21-cv-01456-GBW Document 187 Filed 11/29/22 Page 1 of 9 PageID #: 6916
2. Joinder of Other Parties and Amendment of Pleadings. All motions to join other
parties, and to amend or supplement the pleadings, shall be filed on or before January 6, 2023.
Unless otherwise ordered by the Court, any motion to join a party or motion to amend the pleadings shall be made pursuant to the procedures set forth in Paragraphs 3(h) and 4.
3. Discovery. Unless otherwise ordered by the Court or agreed to by parties, the
limitations on discovery set forth in the Federal Rules of Civil Procedure shall be strictly observed.
(a) Fact Discovery Cut Off. All fact discovery in this case shall be initiated so
that it will be completed on or before December 23, 2022.
(b) Cross-Use of Discovery. The parties hereby agree that any discovery taken
in the arbitration referenced in the complaint shall be deemed to have been taken in this action, and Defendants shall expeditiously provide Plaintiff with copies of any discovery requests, written discovery responses, documents, and deposition transcripts exchanged or taken in the arbitration.
( c) Document Production. Document production shall be substantially complete by November 28, 2022.
( d) Requests for Admission. A maximum of Twenty (20) requests for
admission are permitted for each side.
( e) Interrogatories.
1. A maximum of Twenty (20) interrogatories, including contention
interrogatories, are permitted for each side.
11. The Court encourages the parties to serve and respond to contention
interrogatories early in the case. In the absence of agreement among the parties, contention interrogatories, if filed, shall first be addressed by the party with the burden of proof. The adequacy of all interrogatory answers shall be judged by the level of detail each party provides (i.e., the more detail a party provides, the more detail a party shall receive).
( f) Depositions.
1. Limitation on Hours for Deposition Discovery. Each side is limited to a total of Thirty-Five (35) hours of taking testimony by deposition upon oral examination.
ii. Location of Depositions. Any party or representative ( officer, director, or managing agent) of a party filing a civil action in this district court must ordinarily be required, upon request, to submit to a deposition at a place designated within this district.
Exceptions to this general rule may be made by order of the Court. A defendant who becomes a counterclaimant, cross-claimant, or third-party plaintiff shall be considered as having filed an action in this Court for the purpose of this provision.
(g) Expert Testimony. The parties have agreed that no expert testimony will be
offered in this action.
(h) Discovery Matters and Disputes Relating to Protective Orders.
i. Any discovery motion filed without first complying with the
following procedures will be denied without prejudice to renew pursuant to these procedures.
n. Should counsel find, after good faith efforts - including verbal communications among Delaware and Lead Counsel for all parties to the dispute - that they are unable to resolve a discovery matter or a dispute relating to a protective order, the parties involved
in the discovery matter or protective order dispute shall submit a joint letter in substantially the following form:
Dear Judge Williams:
The parties in the above-referenced matter
write to request the scheduling of a discovery
te I econference.

The following attorneys, including at leastone Delaware Counsel and at least one Lead Counsel per party, participated in a verbal meet-and-confer (in person and/or by telephone) on the following
date(s): _______ _
Delaware Counsel: --------
Lead Counsel: --------
The disputes requiring judicial attention are
listed below:
[provide here a non-argumentative list of disputes
requiring judicial attention]
u1. On a date to be set by separate order, generally not less than fortyeight ( 48) hours prior to the conference, the party seeking relief shall file with the Court a letter,
not to exceed three (3) pages, outlining the issues in dispute and its position on those issues. On a date to be set by separate order, but generally not less than twenty-four (24) hours prior to the conference, any party opposing the application for relief may file a letter, not to exceed three (3) pages, outlining that party's reasons for its opposition.
1v. Each party shall submit two (2) courtesy copies of its discovery
letter and any attachments.
v. Should the Court find further briefing necessary upon conclusion of
the telephone conference, the Court will order it. Alternatively, the Court may choose to resolve the dispute prior to the telephone conference and will, in that event, cancel the conference.
4. Motions to Amend.
(a) Any motion to amend (including a motion for leave to amend) a pleading
shall NOT be accompanied by an opening brief but shall, instead, be accompanied by a letter, not to exceed three (3) pages, describing the basis for the requested relief, and shall attach the proposed amended pleading as well as a "black.line" comparison to the prior pleading.

(b) Within seven (7) days after the filing of a motion in compliance with this
Order, any party opposing such a motion shall file a responsive letter, not to exceed five (5) pages.
(c) Within three (3) days thereafter, the moving party may file a reply letter,
not to exceed two (2) pages, and, by this same date, the parties shall file a letter requesting a teleconference to address the motion to amend.
5. Motions to Strike.
(a) Any motion to strike any pleading or other document shall NOT be
accompanied by an opening brief but shall, instead, be accompanied by a letter, not to exceed three (3) pages, describing the basis for the requested relief, and shall attach the document to be stricken.
(b) Within seven (7) days after the filing of a motion in compliance with this
Order, any party opposing such a motion shall file a responsive letter, not to exceed five (5) pages.
(c) Within three (3) days thereafter, the moving party may file a reply letter,
not to exceed two (2) pages, and, by this same date, the parties shall file a letter requesting ateleconference to address the motion to strike.
6. Case Dispositive Motions.
(a) Absent agreement between the parties, and prior approval from the Court
the Court will not hear case dispositive motions in cases proceeding to a bench trial.
(b) Concise Statement of Facts Requirement. If there 1s agreement
between the parties and prior approval from the Court as required by paragraph 6(a) above, any motion for summary judgment shall be accompanied by a separate concise statement, not to exceed six (6) pages, which details each material fact which the moving party contends is essential for the Court's resolution of the summary judgment motion (not the entire case) and as to which the moving party contends there is no genuine issue to be tried. Each fact shall be set forth in a separate numbered paragraph and shall be supported by specific citation(s) to the record.
Any party opposing the motion shall include with its opposing papers a
response to the moving party's concise statement, not to exceed six (6) pages, which admits or disputes the facts set forth in the moving party's concise statement on a paragraph-by-paragraph basis. To the extent a fact is disputed, the basis of the dispute shall be supported by specific citation(s) to the record. Failure to respond to a fact presented in the moving party's concise statement of facts shall indicate that fact is not in dispute for purposes of summary judgment. The party opposing the motion may also include with its opposing papers a separate concise statement, not to exceed four ( 4) pages, which sets forth material facts as to which the opposing party contends
there is a genuine issue to be tried. Each fact asserted by the opposing party shall also be set forth in a separate numbered paragraph and shall be supported by specific citation(s) to the record.
The moving party shall include with its reply papers a response to the opposing party's concise statement of facts, not to exceed four (4) pages, on a paragraph-byparagraph basis. Failure to respond to a fact presented in the opposing party's concise statement
of facts shall indicate that fact remains in dispute for purposes of summary judgment.
7. Applications by Motion. Except as otherwise specified herein, any application to
the Court shall be by written motion. Any non-dispositive motion should contain the statement required by Local Rule 7 .1.1 .
8. Motions in Limine. Motions in limine shall not be separately filed. All in limine
requests and responses thereto shall be set forth in the proposed pretrial order. Each party shall be
limited to three (3) in limine requests, unless otherwise permitted by the Court The in limine
request and any response shall contain the authorities relied upon; each in limine request may be supported by a maximum of three (3) pages of argument, may be opposed by a maximum of three (3) pages of argument, and the party making the in limine request may add a maximum of one (1) additional page in reply in support of its request. If more than one party is supporting or opposing an in limine request, such support or opposition shall be combined in a single three (3) page submission (and, if the moving party, a single one (1 ) page reply), unless otherwise ordered by the Court. No separate briefing shall be submitted on in limine requests, unless otherwise permitted by the Court.
9. Pretrial Conference. On July 10, 2023, the Court will hold a pretrial conference in
Court with counsel beginning at 4:00 p.m. The parties shall file with the Court the joint
proposed final pretrial order in compliance with Local Rule 16.3(c) and the Court's Preferences and Procedures for Civil Cases not later than seven (7) days before the pretrial conference. Unless otherwise ordered by the Court, the parties shall comply with the timeframes set forth in Local Rule 16.3(d)(l)-(3) for the preparation of the joint proposed final pretrial order. The Court will advise the parties at or before the above-scheduled pretrial conference whether an additional pretrial conference will be necessary.
The parties shall provide the Court two (2) courtesy copies of the joint proposed
final pretrial order and all attachments. The proposed final pretrial order shall contain a table of contents and the paragraphs shall be numbered.
10. Application to Court for Protective Order. Should counsel find it will be necessary
to apply to the Court for a protective order specifying terms and conditions for the disclosure of confidential information, counsel should confer and attempt to reach an agreement on a proposed form of order and submit it to the Court within ten (10) days from the date the Court enters this Order. Should counsel be unable to reach an agreement on a proposed form of order, counsel must follow the provisions of Paragraph 3(g) above.
 Any proposed protective order must include the following paragraph:
Other Proceedings. By entering this order and
limiting the disclosure of information in this case, the
Court does not intend to preclude another court from
finding that information may be relevant and subject
to disclosure in another case. Any person or party
subject to this order who becomes subject to a motion
to disclose another party's information designated
"confidential" [the parties should list any other level
of designation, such as "highly confidential," which
may be provided for in the protective order] pursuant
to this order shall promptly notify that party of the
motion so that the party may have an opportunity to
appear and be heard on whether that information
should be disclosed.
11. Papers Filed Under Seal. In accordance with section G of the Revised
Administrative Procedures Governing Filing and Service by Electronic Means, a redacted version of any sealed document shall be filed electronically within seven (7) days of the filing of the sealed document.
12. Courtesy Copies. The parties shall provide to the Court two (2) courtesy copies of
filings (i.e., briefs, appendices, exhibits, declarations, affidavits etc.). Courtesy copies of
appendices and exhibits should include hard tabs. This provision also applies to papers filed under seal.
13. ADR Process. This matter is not referred to a magistrate judge to explore the
possibility of alternative dispute resolution. If at any time the parties wish to explore alternative dispute resolution with a magistrate judge, they shall so inform the Court.
14. Trial. This matter is scheduled for a three (3) day bench trial beginning at 9:30
a.m. on July 17, 2023, with the subsequent trial days beginning at 9:30 a.m.• The trial will be
Case 1:21-cv-01456-GBW Document 187 Filed 11/29/22 Page 8 of 9 PageID #: 6923
timed, as counsel will be allocated a total number of hours in which to present their respective
cases.

The Honorable Gregory B. Williams
United States District Judge