United States District Court, S.D. New York
May 10, 2005.
IN RE WORLDCOM, INC. SECURITIES LITIGATION. This Document Relates To: IN RE PAINEWEBBER GOALS() LITIGATION.
The opinion of the court was delivered by: DENISE COTE, District Judge
STIPULATION AND [PROPOSED] ORDER
WHEREAS, on August 30, 2004, Plaintiffs moved for Class
WHEREAS, on September 8, 2004 Plaintiffs agreed to withdraw
their motion for class certification, without prejudice, pending
the making of defendants' motions to dismiss; and
WHEREAS, the Court therefore denied Plaintiff's motion for
class certification on October 26, 2004, without prejudice to its
re-institution following the making of any motions to dismiss;
WHEREAS, the time has passed for the making of such motions;
IT IS HEREBY STIPULATED AND AGREED that:
Plaintiffs' class certification motion is deemed re-instituted.
Defendants' response to the class certification motion will be
due June 27, 2005 after it is re-instituted;
Plaintiffs' reply brief will be due on July 27, 2005;
Documentary and email discovery will conclude on September 10,
2005; Fact discovery, including depositions, will conclude on
December 16, 2005;
Expert reports conforming to Fed.R.Civ.P. 26(a)(2)(B) from
those parties bearing the burden of proof on any area in which
they seek to introduce expert testimony are due on January 6,
Rebuttal expert reports conforming to Fed.R.Civ.P.
26(a)(2)(B) are due on February 3, 2006;
Revised expert reports are due on February 24, 2006; and
Expert discovery will conclude on March 17, 2006;
The parties shall notify the Court of the extent to which they
have agreed that the summary judgment Opinions issued in the
Securities Litigation class action shall be deemed to cover the
summary judgment practice in the Individual Actions on December
Summary judgment motions are due on March 17, 2006;
Oppositions to summary judgment motions are due on April 7,
Replies to summary judgment motions are due on April 14, 2006.
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