The opinion of the court was delivered by: Hon. Susan D. Wigenton
PRETRIAL SCHEDULING ORDER
THIS MATTER having come before the Court for a scheduling conference pursuant to Rule 16 of the Federal Rules of Civil Procedure on October 6, 2008; Matthew Pomo, Esq., appearing on behalf of Plaintiff; Leland I. Kellner, Esq., appearing on behalf of the Defendant Hino; Lawrence F. Citro, Esq., appearing on behalf of Defendant Penske; and for good cause shown:
IT IS on this 6th day of October, 2008,
I. DISCOVERY AND MOTION PRACTICE
1. Fact discovery is to remain open through March 1, 2009. No discovery is to be issued or engaged in beyond that date, except upon application and for good cause shown.
2. Any motion to amend pleadings must be filed not later than December 15, 2008.
3. 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). No instruction not to answer shall be given unless a privilege is implicated.
4. Any discovery dispute shall be brought to the Court's attention in the first instance by letter or by telephone conference call immediately after the parties' good faith attempt to resolve the dispute has failed. See L. Civ. R. 16.1(f)(1).
5. Other than as set forth in paragraph 6, no motions shall be filed without leave of Court. If a party wishes to file a motion, he or she should write a letter to the Magistrate Judge explaining the basis of the motion and the Court will advise as to how to proceed.
6. Dispositive motions shall not be filed until thirty (30) days after the close of Discovery. Failure to file dispositive motions within that time frame shall result in their dismissal as untimely.
7. All affirmative expert reports shall be delivered by April 1, 2009, with depositions of those experts to be taken and completed within twenty (20) days of receipt of report. See Fed. R. Civ. P. 26(b) (4) (A). Any such report is to be in the form and content as required by Fed. R. Civ. P. 26(a) (2) (B).
8. All responding expert reports shall be delivered by May 15, 2009, with depositions of those experts to be taken and completed within twenty (20) days of receipt of report. Any such report ...