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Case 3:13-cv-00146-RNC Document 27 Filed 07/24/13 Page 1 of 4




UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT

Plaintiff,


LYNN ANDRUS,


v.

DOONEY & BOURKE, INC. and
PETER DOONEY






Defendants.





























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CIVIL ACTION NO.
3:13-CV-00146 (RNC)







JULY 24, 2013





DEFENDANTS’ STATUS REPORT


Pursuant to the Court’s Scheduling Order Regarding Case Management Plan dated June

18, 2013 (Dkt. No. 23), Defendants Dooney & Bourke, Inc. (“Dooney & Bourke”) and Peter

Dooney (“Mr. Dooney”) (collectively referred to hereinafter as “Defendants”) hereby submit this

status report.1

A.

Status of the Case.

1.

Discovery undertaken to date.

Defendants will serve their First Set of Interrogatories and Requests For Production to

Plaintiff in August, 2013.





2.

Discovery that remains to be completed.



i.

Discovery to be completed by Plaintiff. Plaintiff intends to take up to ten

(10) depositions of fact witnesses.



1 Undersigned counsel for Defendants attempted to contact counsel for the Plaintiff

regarding this report on July 17, 2013. Undersigned counsel for Defendants has not yet received
a response to his email or voicemail and, therefore, is filing the attached as Defendants’ Status
Report rather than as a joint report.


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Case 3:13-cv-00146-RNC Document 27 Filed 07/24/13 Page 2 of 4







ii.

Discovery to be completed by Defendants. Defendants intend to take

Plaintiff’s deposition. In addition to Plaintiff, Defendants intend to take up to nine (9) other

depositions of fact witnesses and the deposition of any expert witnesses designated by Plaintiff.

Defendants expect to complete such depositions before January 31, 2014. Defendants reserve

the right to serve supplemental interrogatories and requests for production on Plaintiff within the

discovery period established by the Case Management Plan.





3.

Pending/anticipated motions.



By Defendants. No pending or anticipated motions at the time, but Defendants

reserve their right to move for summary judgment based upon the discovery in this matter.



4.

Circumstances potentially interfering with the parties’ compliance with the

Scheduling Order. Defendants are committed to completing discovery within the time frame

established by the Court.



B.

Referral to Magistrate Judge for settlement purposes.



Defendants do not request a referral to a Magistrate Judge for settlement purposes until

after the completion of discovery in this matter.



C.

Trial before Magistrate Judge.

Defendants do not consent to trial before a Magistrate Judge.

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Case 3:13-cv-00146-RNC Document 27 Filed 07/24/13 Page 3 of 4



D.

Estimated length of trial.







Defendants estimate that the trial of this matter would require four to five days.

DEFENDANTS,
DOONEY & BOURKE, INC. AND
PETER DOONEY

By: /s/ Daniel L. Schwartz
Daniel L. Schwartz, Esq. (ct09862)
Day Pitney LLP
One Canterbury Green
Stamford, CT 06901
Telephone: (203) 977-7300
Facsimile: (203) 977-7301
[email protected]


By: /s/ Thomas J. McAndrew
Thomas J. McAndrew, Esq.
Thomas J. McAndrew, Esq. & Associates
One Turks Head Place, Suite 205
Providence RI 02903
Telephone: (401) 455-0350
Facsimile: (401) 455-0882
[email protected]
ADMITTED PRO HAC VICE
Attorneys for Defendants






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Case 3:13-cv-00146-RNC Document 27 Filed 07/24/13 Page 4 of 4

ELECTRONIC CERTIFICATE OF SERVICE





I hereby certify that on July 24, 2013, a copy of the foregoing Defendants Status Report

was filed electronically and served by mail on anyone unable to accept electronic filing. Notice
of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing
system or by mail to anyone unable to accept electronic filing as indicated on the Notice of
Electronic Filing. Parties may access this filing through the Court’s CM/ECF System.







/s/ Daniel L. Schwartz
Daniel L. Schwartz




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