DISCOVERY PLAN

The parties will submit their respective Rule 26 Self Disclosures by July 1, 2017.

The parties will conduct fact discovery with written discovery to commence on
or after July 15, 2017, and be completed by October 31,2017.

Depositions may commence on or after November 1,2017, and are to be completed by January 15, 2018.

Any and all discovery demands previously served on either party shall be re-served following court approval of this discovery
scheduling plan.

Each party will file expert disclosures pursuant to Federal Rule of Civil
Procedure 26(a)(2) on any issue in which they have the affirmative burden of
proof by March 15,2018,

Responsive Expert Reports will be filed by April 30,2018,

Expert Depositions will be taken after all reports are received but
before May 31 ,2018.

Limits of ten (10) depositions per side and twenty (20) interrogatories, twenty
(20) requests to admit, and twenty (20) document requests per party will
apply.

There are no other matters of discovery pertinent at this time.

Mediation shall be completed no later than November 15,2017.

MOTIONS

All dispositive motions shall be filed no later than June 30, 2018.

TRIAL DATE
The earliest date by which this case should be reasonably expected to be ready
for trial shall be September, 2018.

LENGTH OF TRIAL
The estimated length of time expected to try the case to verdict is three (3) days.

OTHER MATTERS
None anticipated at this time.

Word Version of Complaint

Summons