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MCR shall conduct all discovery so that it shall be complete not less than <br /> thirty (30) days prior to the trial date. <br /> Counsel for MCR certifies he advised his clients of the estimated costs and <br /> attorney fees involved in its discovery. <br /> C. DMG Discovery <br /> DMG agrees to comply with the following discovery schedule unless <br /> otherwise ordered by this Court: <br /> As to Plaintiffs: <br /> 1. Initial interrogatories, requests for production of documents, and <br /> requests for admissions to Plaintiffs 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 Plaintiffs shall be <br /> served no later than seventy-five (75) days prior to trial, which date <br /> may be adjusted depending upon the sufficiency and thoroughness <br /> of Plaintiffs' answers or responses or the need to compel under the <br /> discovery rules. <br /> 3. Depositions of Plaintiffs' principal representative(s) (who shall be <br /> designated by Plaintiffs on or before February 2, 1998) shall occur <br /> no 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 Plaintiffs' expert witness(es) shall occur no later <br /> than June 1, 1998. <br /> As to MCR <br /> 6. 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 /> 7. 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 /> 8 <br />