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1. Initial interrogatories, requests for production of documents, and <br /> requests for admissions to MCR shall be served no later than <br /> March 5, 1999. <br /> 2. One set of follow-up interrogatories, requests for production of <br /> documents, and requests for admissions to MCR shall be served <br /> no later than April 26, 1999. <br /> 3. Depositions of MCR's Representatives shall occur no later than <br /> July 9, 1999. <br /> 4. Depositions of two (2) other witnesses shall occur no later than <br /> July 9. 1999. <br /> 5. Depositions of expert witnesses shall occur no later than July <br /> 30, 1999. <br /> Pitkin County shall conduct all further discovery so that it shall be completed not less <br /> than thirty (30) days prior to the trial date. <br /> Counsel for Pitkin County 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 /> VI. <br /> PRETRIAL MOTIONS <br /> All motions for partial summary judgment shall be filed on or before thirty (30) days <br /> after completion of discovery. All other pretrial motions shall be filed no later than sixty <br /> (60) days prior to the date set for trial of this matter. <br /> VII. <br /> SETTLEMENT <br /> The parties affirm that they have discussed settlement and will continue to do so. <br /> 6 <br />