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MCR shall conduct all further discovery so that it shall be completed not less <br /> than thirty (30) days prior to the trial date set herein. <br /> Counsel for MCR certifies that he has advised his clients of estimated costs <br /> and attorneys' fees involved in this discovery. <br /> B. DMG Discovery <br /> DMG agrees 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 December <br /> 14, 1998. <br /> 2. One set of follow-up interrogatories,requests for production <br /> documents, and requests for admissions to MCR shall be served no later <br /> than February 11, 1999. <br /> 3. Depositions of MCR's principal representative(s) shall occur no later <br /> than May 7, 1999. <br /> 4. Depositions of two (2) other witnesses shall occur no later than May 7, <br /> 1999. <br /> 5. Depositions of MCR's expert witness(es) shall occur no later than May <br /> 29, 1999. <br /> DMG shall conduct all further discovery so that it shall be completed not less <br /> than thirty (30) days prior to the trial date set herein. <br /> Counsel for DMG certifies that she has advised her clients of estimated costs <br /> and attorneys' fees involved in this discovery. <br /> V. <br /> TIME TO JOIN ADDITIONAL PARTIES .AND AMEND PLEADINGS <br /> Any additional parties shall be joined no later than 90 days before trial. Likewise, any <br /> motion to amend shall be filed and served no later than 90 days before trial. <br /> 5 <br />