The opinion of the court was delivered by: Esther Salas United States Magistrate Judge
PRETRIAL SCHEDULING ORDER
THIS MATTER having come before the Court for a scheduling conference pursuant to Fed. R. Civ. P. 16 on August 12, 2008; and for good cause shown,
IT IS on this 12th day of August , 2008, ORDERED THAT:
I. DISCOVERY AND MOTION PRACTICE
1. Fact Discovery Deadline. Fact discovery is to remain open through February 12, 2009. All fact witness depositions must be completed by the close of fact discovery. No discovery is to be issued or engaged in beyond that date, except upon application and for good cause shown.
2. Motions to Add New Parties. Any motion to add new parties, whether by amended or third-party complaint, must be returnable no later than November 7, 2008.
3. Motions to Amend Pleadings. Any motion to amend pleadings must be returnable no later than November 7, 2008.
4. Rule 26 Disclosures. The parties shall exchange disclosures as required pursuant to Fed. R. Civ. P. 26 no later than August 22, 2008.
5. Interrogatories. The parties may serve interrogatories limited to twenty-five (25) single questions, including subparts and requests for production of documents, on or before September 12, 2008,which shall be responded to by October 13, 2008.
6. Depositions. The number of depositions to be taken by each side shall not exceed ten (10). No objections to questions posed at depositions shall be made other than as to lack of foundation, form, or privilege. See Fed. R. Civ. P. 32(d)(3)(A).
7. Electronic Discovery. The parties are directed to Fed. R. Civ. P. 26(f), as amended December 1, 2006, which, among other things, addresses preservation of discoverable information, discovery of electronically stored information, and claims of privilege or work product protection. The parties are also directed to L. Civ. R. 26.1(d) which, among other things, describes the obligations of counsel with regard to their clients' information management systems.
8. Discovery Disputes. No discovery motion or motion for sanctions for failure to provide discovery shall be made without prior leave of Court. Counsel shall confer in good faith and attempt to informally resolve any discovery disputes before seeking the Court's intervention. Should such informal efforts fail, the aggrieved party shall bring the dispute to the Court's attention in the first instance by a brief letter, not to exceed 5 pages, outlining the dispute. The other party will then be permitted to submit a brief opposition letter, not to exceed 5 pages. Thereafter, the Court will schedule a telephonic discovery conference pursuant to Fed. R. Civ. P. 26(f) to resolve the dispute. See L. Civ. R. 16.1(f).
9. Motion Practice. No motions are to be filed without prior written permission from this Court. All dispositive motions must first be the subject of a dispositive motion pre-hearing. These pre-requisites must be met before any motions are filed and the motions will be returned if not met. All calendar or dispositive motions, ...