UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORKPlaintiff,-V-Defendant.Case No. Civ.(KMK)( )CASE MANAGEMENT AND SCHEDULING ORDER KENNETH M. KARAS, District Judge: At the conference before the Court held on this Case Management Plan and Scheduling Order was adopted in accordance with Rules 16-26(f) of theFederal Rules of Civil Procedure. This case (is) (is not) to be tried to a jury [circle one].No additional parties may be joined except with leave of the Court.Amended pleadings may not be filed except with leave of the Court.Initial disclosure pursuant to Rule 26(a)(1), Fed. R. Civ. P., will be completed notlater than [absent exceptional circumstances, withinfourteen (14) days of the date of the parties222 conference pursuant to Rule 26(f)].All fact discovery is to be completed no later than [aperiod not to exceed 120 days unless the Court finds that the case presents uniquecomplexities or other exceptional circumstances].The parties are to conduct discovery in accordance with the Federal Rules of CivilProcedure and the Local Rules of the Southern District of New York. Thefollowing interim deadlines may be extended by the parties on consent withoutapplication to the Court, provided the parties meet the fact discovery completiondate in paragraph 6 above:Initial requests for production of documents to be served by . American LegalNet, Inc. www.FormsWorkFlow.com American LegalNet, Inc. www.FormsWorkFlow.com b.Interrogatories to be served by .c.Depositions to be completed by .i.Unless the parties agree or the Court so orders, depositions are notto be held until all parties have responded to initial requests for documentproduction.ii.There is no priority in deposition by reason of a party222s status asplaintiff or defendant.iii.Unless the parties agree or the Court so orders, non-partydepositions shall follow initial party depositions.d.Requests to Admit to be served no later than .7.All expert disclosures, including reports, production of underlying documents anddepositions are to be completed by:a.Expert(s) of Plaintiff(s) .b.Expert(s) of Defendant(s) .8.Motions: All motions and applications shall be governed by the Court222sIndividual Practices, including pre-motion conference requirements. SummaryJudgment or other dispositive motions are due at the close of discovery. Pursuantto the undersigned222s Individual Practices, the parties shall request a pre-motionconference in writing at least two (2) weeks prior to this deadline.9.All counsel must meet for at least one hour to discuss settlement not later thantwo weeks following the close of fact discovery. 10.a.Counsel for the parties have discussed holding a settlement conferencebefore a Magistrate Judge. b.11.a.The parties (request) (do not request) a settlement conference before aUnited States Magistrate Judge [circle one].Counsel for the parties have discussed the use of the Court222s MediationProgram.b.The parties (request) (do not request) that the case be referred to theCourt222s Mediation Program [circle one].Page 2 of 412.a.Counsel for the parties have discussed the use of a privately-retainedmediator.b.The parties (intend) (do not intend) to use a privately-retained mediator[circle one].13.The parties shall submit a Joint Pretrial Order prepared in accordance with theundersigned222s Individual Practices and Rule 26(a)(3), Fed.R.Civ.P. If this actionis to be tried before a jury, proposed voir dire, jury instructions and a verdict formshall be filed with the Joint Pretrial Order. Counsel are required to meet andconfer on jury instructions and verdict form in an effort to make an agreed uponsubmission.14.Parties have conferred and their present best estimate of the length of trial is .Page 3 of 4 American LegalNet, Inc. www.FormsWorkFlow.com Page 4 of 4 American LegalNet, Inc. www.FormsWorkFlow.com TO BE COMPLETED BY THE COURT:15.[Other directions to the parties:]There will be no extensions of the deadline for completion of discovery past the datediscovery is scheduled to be completed in this Order without the permission of the Court,nor should counsel assume that any extensions will be granted. Counsel may seekpermission for extension of interim discovery deadlines from the magistrate judge to whomthe case is referred. Counsel may seek permission for an extension of the deadline forcompletion of discovery past the date discovery is scheduled to be completed in this Orderonly after consenting to allowing the magistrate judge to handle the case for all purposes.16.The next Case Management Conference is scheduled for .The movant222s pre-motion letter is due ; The non-movant222s response is due .SO ORDERED.DATED:White Plains, New York