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IV. <br /> DISCOVERY SCHEDULE <br /> The parties currently believe that discovery in excess of the limitations set forth in <br /> Rule 26(b)(2), COLO. R. Civ. P., including depositions and written discovery, will not be <br /> necessary in this case. Because the parties will be actively pursuing settlement over the <br /> next sixty (60) days, all have agreed to delay active discovery until after February 2, 1998. <br /> A. Plaintiffs' Discovery <br /> Plaintiffs agree to comply with the following discovery schedule unless <br /> otherwise ordered by this Court: <br /> 1. Initial interrogatories, requests for production of documents, and <br /> requests for admissions to MCR shall be served no later than <br /> February 2, 1998. <br /> 2. One set of follow-up interrogatories, requests for production of <br /> documents, and requests for admissions to MCR shall be served no <br /> later than seventy-five (75) days prior to trial, which date may be <br /> adjusted depending upon the sufficiency and thoroughness of <br /> MCR's answers or responses or the need to compel under the <br /> discovery rules. <br /> 3. Depositions of MCR's Representative (to be designated by MCR <br /> by February 2, 1998), and Defendant Louis LaGiglia shall occur no <br /> later than May 1, 1998. <br /> 4. Depositions of two (2) other witnesses shall occur no later than <br /> June 1, 1998. <br /> 5. Depositions of expert witnesses shall occur no later than June 1, <br /> 1998. <br /> Plaintiffs shall conduct all further discovery so that it shall be completed <br /> not less than thirty (30) days prior to the trial date set herein. <br /> Counsel for Plaintiffs certifies that she has advised her clients of estimated <br /> costs and attorneys' fees involved in this discovery. <br /> B. Defendants' Discovery <br /> MCR agrees to comply with the following discovery schedule unless <br /> otherwise ordered by this Court: <br /> 6 <br />