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Case 3:13-cv-00146-RNC Document 28 Filed 07/24/13 Page 1 of 4

UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT

LYNN ANDRUS, (cid:9)

Plaintiff,

V.

DOONEY & BOURKE, INC. and
PETER DOONEY

Defendants.

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

JULY 24, 2013

JOINT STATUS REPORT

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

18, 2013 (Dkt. No. 23), Plaintiff Lynn Andrus and Defendants Dooney & Bourke, Inc. ("Dooney

& Bourke") and Peter Dooney ("Mr. Dooney") (collectively referred to hereinafter as

"Defendants") jointly and respectfully submit this status report.

A. (cid:9)

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. Plaintiff will serve her First Set of Interrogatories and Requests For

Production to Defendants in August, 2013

2.

Discovery that remains to be completed.

i. (cid:9)

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

(10) depositions of fact witnesses.

Discovery to be completed by Defendants. Defendants will notice and

intend to take Plaintiff's deposition. In addition to Plaintiff, Defendants expect to take up to ten

(10) depositions of fact witnesses and the deposition of any expert witnesses designated by

Case 3:13-cv-00146-RNC Document 28 Filed 07/24/13 Page 2 of 4

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.

i. (cid:9)

By Plaintiff No pending or anticipated motions at this time but the

Plaintiff reserves her right to move for summary judgment based upon the discovery in this

matter.

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 intelfering with the parties' compliance with the

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

established by the Court.

B.

Referral to Magistrate Judge for settlement purposes.

The parties 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.

The parties do not consent to trial before a Magistrate Judge.

Case 3:13-cv-00146-RNC Document 28 Filed 07/24/13 Page 3 of 4

D. (cid:9)

Estimated length of trial.

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

PLAINTIFF,
LYNN ANDRUS

By: /s/ Timothy J. McGuire

Timothy J. McGuire, Esq. (ct28049)
Halloran & Sage, LLP
315 Post Road West
Westport, CT 06880
Telephone: (203) 227-2855
Facsimile: (203) 227-6992
[email protected]
Attorneys for Plaintiff

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
dIschwartz(iD,davpitnev.com

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

Case 3:13-cv-00146-RNC Document 28 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 Joint 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/ Timothy J. McGuire
Timothy J. McGuire