Case 1:15-cv-00477-LMM Document 22 Filed 04/28/15 Page 1 of 3

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
KELVIN J. COCHRAN,

Plaintiff,

Case No. 1:15-cv-00477-LMM

v.
CITY OF ATLANTA, GEORGIA;
and MAYOR KASIM REED, IN
HIS INDIVIDUAL CAP ACITY,

Defendants.
Joint Preliminary Report and Discovery Plan 1

PLEASE TAKE NOTICE THAT counsel for Plaintiff has been unable,

despite repeated efforts, to obtain final assent or objection from counsel for
Defendants regarding this preliminary report and discovery plan.

Counsel

for Plaintiff understands that Mr. Robert N. Godfrey, lead counsel for
Defendants, has been out of the office and believes that this has resulted in
the issue presented. Counsel for both parties did, however, have an amicable
Rule 26() conference on April 10, 2015.

Counsel for Plaintiff trusts that

counsel for Defendants will inform this Court and counsel for Plaintiff
whether they agree with or object to the contents of this document.
1

Case 1:15-cv-00477-LMM Document 22 Filed 04/28/15 Page 2 of 3

*************

SCHEDULING ORDER
Upon review of the information contained in the Joint Preliminary
Report and Discovery Plan form completed and filed by the parties, the Court
orders that the time limits for adding parties, amending the pleadings, filing
motions, completing discovery, and discussing settlement are as set out in the
Federal Rules of Civil Procedure and the Local Rules of this Court, except as
herein modified:
1. The discovery period is extended up to and including December 24,
2015.
2. Plaintiff must designate experts and, unless otherwise stipulated,
submit written reports from testifying experts by August 25, 2015.
3. Defendants must designate experts and, unless otherwise stipulated,
submit written reports from testifying experts by September 25, 2015.
4. Plaintiff must

designate

rebuttal

experts

and,

unless

otherwise

stipulated, submit written reports from testifying rebuttal experts by

October 26, 2015.
5. Motions to compel must be filed on or before December 24, 2015 or
within fourteen (14) days after service of the disclosure or discovery
response upon which the motion is based, whichever is later.
6. Motions for summary judgment must be filed on or before January 25,
2016.
7. A proposed pretrial order shall be filed on or before January 25, 2016 or

within thirty (30) days of the Court's ruling on any pending motion for
summary judgment, whichever is later.

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..

Case 1:15-cv-00477-LMM Document 22 Filed 04/28/15 Page 3 of 3

8. If Plaintiff receives a right-to-sue letter from the Equal Employment

Opportunity Commission, the Plaintiff is permitted to amend the

Verified Complaint to add any claims and associated damages that
become available as a result of the letter.

IT IS SO ORDERED, this

2J

day of

4imTAfiltfrsTRICT

13

/}yr\)

JUDGE

'2015.