Plaintiff's counsel proposes a simultaneous exchange of opening expert reports on 15 January and a 60-page limit excluding exhibits.
Plaintiff's associate proposes dates for five fact-witness depositions over two weeks in November and asks for the witnesses' availability.
Plaintiff's counsel proposes twelve custodians and a date range of January 2021 to June 2023 for the first production, and asks for a call this week.
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