1997-11-03_GENERAL DOCUMENTS - C1981017

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MCR's answers or responses or the need to compel under the discovery rules. 8. Depositions of MCR's principal representative(s) (who shall be designated by MCR on or before February 2, 1998) shall occur no later than May 1, 1998. 9. Depositions of two (2) other witnesses shall occur no later than June 1, 1998. 10. Depositions of MCR's expert witness(es) shall occur no later than June 1, 1998. DMG shall conduct all further discovery so that it shall be completed not less than thirty (30) days prior to the trial date set herein. Counsel for DMG certifies that she has advised her clients of estimated costs and attorneys' fees involved in this discovery. V. TIME TO JOIN ADDITIONAL PARTIES AND AMEND PLEADINGS The parties anticipate that following discovery there will be a need to amend pleadings, to amend claims, assert cross-claims, assert counter-claims, seek joinder of third parties, or designate other non-parties. The parties agree to allow motions for such amendments after discovery. All such motions for amendments to the pleadings shall be made on or before sixty (60) days before trial. VI. PRETRIAL MOTIONS Plaintiffs anticipate filing a motion for partial summary judgment no later than thirty (30) days after completion of discovery. All other pretrial motions shall be filed no later than sixty (60) days prior to the date set for trial of this matter. VII. SETTLEMENT A. Between Plaintiffs and MCR Settlement negotiations between Plaintiffs and MCR have been ongoing since the summer of 1996 and are continuing. Plaintiffs and MCR will schedule a settlement conference before a Judge in this judicial district (not sitting for this matter) or other alternative dispute resolution organization qualified for this purpose to supervise such conference within sixty (60) days of this order. 9