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)
DOONEY & BOURKE, INC. and
CIVIL ACTION NO.
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.
Status of the Case.
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
Discovery that remains to be completed.
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.
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
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
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.
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.
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
Estimated length of trial.
The parties estimate that the trial of this matter would require four to five days.
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
Attorneys for Plaintiff
DOONEY & BOURKE, INC. AND
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
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
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