1. All initial disclosures pursuant to V.I. R.Civ.P. 26(a) shall be served on all parties not later than February 28, 2018.
2. All written interrogatories, requests for production of documents, and requests for
admissions shall be propounded not later than April 2, 2018.
3. No party shall propound more than 25 interrogatories, 25 requests for production of
documents, and 25 requests for admissions, including all discrete subparts thereof,
unless otherwise stipulated by the parties or ordered by the court.
4. All motions to amend the pleadings to add claims, defenses, and/or parties shall be
filed and served no later than April 16, 2018. All fact witness deposition, including
depositions of nonparties, taken for purposes of discovery and/or to preserve
testimony for trial shall be completed by August 1, 2018.
5. No party shall take more than ten (10) fact and expert witness depositions, no single
deposition shall exceed more than seven (7) hours in durations, and any single
deposition shall be completed on the same day on which it is commenced, unless otherwise
stipulated by the parties or ordered by the court.
6. All motions to compel, for discovery, sanctions, or for protective orders with respect to
all initial disclosures and fact discovery, shall be filed and served no later than May
1, 2018.
7. The parties' first mediation session shall be commenced and completed not later than July 1, 2018.
8. All Parties shall serve notices identifying all of their expert witnesses, and said expert
witnesses' curriculum vitae and written reports on any issue in which they have the burden of
proof, not later than April 30, 2018.
9. All Parties shall serve notices identifying all of their rebuttal/expert witnesses,
and said expert witnesses' curriculum vitae and written reports, not later than September 30,
2018.
10. All expert witness deposition, for purposes of discovery and to preserve testimony for
trial, shall be completed not later than October 31, 2018.
11. All motions to compel, for sanctions, or for protective orders with respect to expert
discovery, shall be filed and served not later than November 15, 2018.
12. All dispositive motions, except for motions challenging subject matter jurisdiction
which may be filed at any time, and Daubert/Kuhmo motions shall be filed and served
not later than November 15, 2018.
13. All motions in limine and V.I. Rule of Evidence 104 motions shall be filed and served not later
than December 14, 2018.
14. This Joint Discovery and Scheduling Plan may not be amended, except as ordered by
the court for good cause shown.
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