(Formerly NCDA / NFGE)




Court Calendar for the Lawsuit


Stipulated Discovery Plan of NCDA Lawsuit

This is a sysnopsy of the plan filed Feb 18, 1998 in US District
Court,District of Nevada. CV-N-97-00573-ECR (RAM)

Oct    8, 1997      Status of Pleading: Original Complaint filed

Feb   3, 1998      Joint Motion filed to defer jurisdictional briefing and                                  discovery until plaintiffs request for certification has                                  been ruled upon by the court

Feb   9, 1998      A meeting was held in Reno, Nevada. All parties were
                                notified or present. All parties agreed to a stay of                                  discovery  until the class certification would be ruled upon.

Feb 18, 1998      Plan is received in US District Court

Mar 16, 1998      Defendants propounded their initial set of                                 interrogatories and document requests.

Mar 16, 1998      Each named plaintiff must provided defendants with 
                                executed authorizations for the release and of all medical,                                 prescriptions, psychiatric, employment, insurance, military,                                 worker's compensation, tax, social security, union, and                                 educational records; and a list of all his/her treating                                 physicians, psychologists, medical facilities where
                                he/she has received treatment, pharmacies, employers,                                 union affiliations and educational institutions.

April 13,1998      Plaintiffs must identify by name and subject of all affiants in                                  support of their motion of class certification

April 16,1998      Plaintiffs must respond to defendants by this date

May 1,   1998      Any amended complaints must be filed

May 12, 1998      Plaintiffs may propound one set of interrogatories relating to                             class certification to the defendants.

May 12, 1998      Defendants may propound and additional set of up to 25                                  interrogatories.

May 25, 1998      Defendants must identify by name and subject all persons                                  intended to oppose class certification.

June 12,1998      Plaintiffs must respond by this date.

June 12,1998      Defendants must respond by this date.

June 15,1998      Plaintiffs must provide financial identification of all persons                                  to be used as affiants.

June 15,1998
        through
  Sept. 15,1998
     The deposition period.

June 29, 1998      Defendants must provide financial identification off all                                   persons to be used as affiants in opposition.

Written Discovery

Aug  01, 1998       Deposition of Plaintiffs must be completed

Sept. 15,1998      Any party wishing to depose any of the affiants must                                  complete all depositions by this date Class                                               Certification  briefing

Oct  15,  1998       Plaintiffs will file their motion for class certification and                                    brief by this date.

Nov 15, 1998         Defendants shall file their responses by this date.

Additional Information:
Full plan in zip format


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