UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY
June 29, 2011
RE: JOSEPH FIGUEROA
PRECISION SURGICAL, INC.
The opinion of the court was delivered by: Douglas E. Arpert, U.S.M.J. United States Magistrate Judge
CHAMBERS OF CLARKSON S. FISHER Douglas E. COURTHOUSE Arpert 402 E. State Street UNITED STATES M AGISTRATE ROOM 6000 JUDGE Trenton, NJ 08608 609-989-2144
Consistent with Magistrate Judge Salas' prior directive [dkt. no. 51]; and the Court having been advised that the parties have met and conferred with respect to certain issues and have not been able to resolve them; it is therefore ORDERED that The parties will prepare and file a joint submission outlining any and all pending discovery disputes.
1) The joint submission shall be in the following format:
a. Disputes Regarding Documents. The parties shall prepare a three-column joint table. Each row of this joint table must: (i) identify a document or category of documents in dispute (if possible by bates-range), (ii) provide a brief synopsis of the complaining party's position, and (iii) provide a brief synopsis of the responding party's position. The brief synopsis should include references to the appendices prepared pursuant to paragraphs 3(d) and 3(e) of this Order, the memoranda of law prepared pursuant to paragraph 3(c) of this Order, and letters already submitted to this Court. If a claim of privilege is being asserted, the complaining party shall submit the privilege log associated with each document in question. The parties should also be prepared to argue the relevance of the documents.
b. Disputes Regarding Interrogatories. The parties shall prepare a three-column joint table. Each row of this joint table must: (i) identify an interrogatory in dispute, (ii) provide a brief synopsis of why the party propounding said interrogatory believes the response is inadequate, (iii) provide a brief synopsis of why the responding party believes the response is sufficient. The brief synopsis should include references to the appendices prepared pursuant to paragraphs 3(d) and 3(e) of this Order, the memoranda of law prepared pursuant to paragraph 3(c) of this Order, and letters already submitted to this Court.
c. Joint Memorandum of Law. The parties must submit a joint memorandum of law, which coincides with the joint tables, to supplement any position taken in either of the joint tables with more extensive legal argument that cites to relevant case law.
d. Joint Appendix. The parties shall compile in a single binder all documents, with the exception of documents subject to claims of privilege or work-product protection, that the Court must consider to resolve the pending discovery disputes.
e. Confidential Appendix. Each party shall also compile in a separate binder all documents subject to disputes regarding privilege or work product protection that the Court must consider in camera to resolve the pending discovery disputes.
2) Each party shall deliver their portion of the submission to the other on or before July 8, 2011.
3) The joint submission is due to this Court on or before July 22, 2011 The submission does NOT need to be e-filed; please simply forward an original and a courtesy copy to the Court.
4) Oral Argument regarding the joint submission will occur by telephone on August 17, 2011 at 11:30 A.M.. Counsel for the Plaintiff is responsible for setting up and initiating call. Please call (609) 989-2144.
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