The opinion of the court was delivered by: Hon. William H. Walls
ORDER AND ORDER ON ORAL MOTION
THIS MATTER having come before the Court for a scheduling conference pursuant to Rule 16 of the Federal Rules of Civil Procedure on March 12, 2009; and for good cause shown:
IT IS on this 13th day of March, 2009
1. Fed. R. Civ. P. 26 disclosures have been exchanged.
2. Fact discovery is to remain open through September 30, 2009. No discovery is to be issued or engaged in beyond that date, except upon application and for good cause shown.
3. The parties may serve interrogatories limited to twenty-five (25) single questions and requests for production of documents and requests to admit on or before March 19, 2009 to be responded to within thirty (30) days of receipt.
4. Depositions of fact witnesses and individuals who will give lay opinion testimony based on particular competence in an area (including but not limited to treating physicians) are to be completed by September 30, 2009. 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.
5. 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). Discovery disputes shall be brought to the court's attention no later than thirty days prior to the close of discovery.
6. No discovery motion or motion for sanctions for failure to provide discovery shall be made without prior leave of Court.
III. DISCOVERY CONFIDENTIALITY ORDERS
7. Any proposed confidentiality order agreed to by the parties must strictly comply with Fed.R.Civ.P. 26(c) and Local Civil Rule 5.3. See also Pansy v. Borough of Stroudsburg, 23 F.3d 772 (3d Cir. 1994); Glenmede Trust Company v. Thompson, 56 F.3d 476 (3d Cir. 1995). Any such form of order must be accompanied by an affidavit or attorney certification filed electronically under the designation "affidavit/certification in support of discovery confidentiality order." The affidavit or attorney certification shall describe (a) the nature of the materials to be kept confidential, (b) the legitimate private or public interests which warrant confidentiality and (c) the clearly defined ...