The opinion of the court was delivered by: Hon. William J. Martini
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 August 19, 2011, Daniel Bevere, Esq. appearing on behalf of Plaintiff and Bryan M. Shay, Esq. appearing on behalf of Defendants; and for good cause shown:
1. Fed. R. Civ. P. 26 disclosures are to be exchanged on or before August 19, 2011.
2. Fact discovery is to remain open through April 1, 2012.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 on or before September 15, 2011, to be responded to within thirty (30) days of receipt.
4. 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).
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 L. Civ. R. 5.3. See also Pansy v. Borough of Stroudsburg, 23 F.3d 772 (3d Cir. 1994); Glenmede Trust Co. 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 ...