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37
ATTACHMENT A: SCHEDULE
Roman type indicates dates ordered by the Court. Italic type indicates additional dates agreed to by the parties.All dates remain subject to Court discretion. State Plaintiffs requested by letter dated June 26, 2012 to have all issues of liability andinjunctive relief in the State Action tried to the Court concurrently with the DOJ Action.Joint Initial Report and Joint Electronic Discovery Submission No. 1 and [Proposed] Order (“ESIOrder”) filedJune 15, 2012 (refiled as amendedJuly 6, 2012)Custodian Lists served
 June 20, 2012
Initial disclosures served (on or about)
 June 22, 2012
Answers to Second Amended Complaint in State Action filed
 June 22, 2012
Court status conference June 22, 2012Parties serve objections to any other party’s document production plan (ESI Order, item 6(a)) andCustodian List
 July 6, 2012
Last date to complete the meet-and-confer process on document production plan objections
 July 18, 2012
Parties to contact chambers of the Honorable Kimba Wood to schedule settlement discussions July 20, 2012Parties to complete initial document collection and provide information set forth in ESI Order at6(a)
 July 31, 2012
[Interim dates for rolling document production and check-in conferences]
[TBA]
DOJ to file motion for proposed final judgment against Settling Defendants (Tunney Act Motion) August 3, 2012Stay as to Settling Defendants expires August 10, 2012Oppositions to Tunney Act Motion August 15, 2012
Case 1:11-md-02293-DLC Document 193-1 Filed 07/06/12 Page 1 of 3
 
 
38States to file motion for preliminary approval of settlement with Settling Defendants August 20, 2012DOJ Reply on Tunney Act Motion August 22, 2012Fact depositions may begin
September 17, 2012
Initial trial witness lists due
 December 18, 2012
Parties to identify experts and testimony subject matter pursuant to Joint Initial Report 8(b)
 
 November 16, 2012Opening class certification brief served November 16, 2012Opposition to class certification brief served December 14, 2012Reply brief on class certification brief served January 18, 2013Privilege logs served
 January 9, 2013
Opening expert reports served January 25, 2013Rebuttal expert reports served February 15, 2013End of fact and expert discovery March 22, 2013
Dates below apply to the DOJ Action only, unless ordered otherwise by the Court
Joint Preliminary Trial Report (including Proposed Findings of Fact, Conclusions of Law,Memoranda of Law, direct testimony affidavits, and deposition designations) filed or served, asstated in Court’s June 25, 2012 Scheduling Order April 26, 2013In limine motions filed April 26, 2013Parties to file list of affiants to be cross-examined May 1, 2013Parties to file responsive memoranda of law (if any) May 3, 2013In limine motion oppositions filed May 3, 2013In limine motion replies filed May 8, 2013
Case 1:11-md-02293-DLC Document 193-1 Filed 07/06/12 Page 2 of 3
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