Text of Proposed Scheduling Order — Carr v. Kabbage, Inc. (Dkt. 15-1, N.D. Ga. No. 1:22-cv-01249)

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U.S. District Court for the Northern District of Georgia · No. 1:22-cv-01249-VMC · Doc. 15-1 · 2022-06-29 · Docket on CourtListener

Full text

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IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF GEORGIA 
ATLANTA DIVISION 
 
Jason Carr, Vicki LeMaster, Edward Ford 
Services LLC, Carlton Morgan¸ 365 Sun 
LLC and Candice Worthy, individually and 
on behalf of all others similarly situated, 
Plaintiffs, 
v.  
Kabbage, Inc. d/b/a K Servicing, 
Defendant. 
 
 
         Civil Action  
No.1:22-cv-01249-VMC 
 
 
 
[PROPOSED] SCHEDULING ORDER 
The parties respectfully submit the following proposed Scheduling Order for 
the Court’s consideration.  Having considered the parties’ joint request and for good 
cause shown, it  is hereby ORDERED that the following schedule shall apply to this 
matter: 
EVENT 
DUE DATE 
1. Joint Preliminary Report and Discovery 
Plan required by Local Rule 16.2 
6/29/2022 
2. Initial Disclosures required by Local 
Rule   26.1 
6/29/2022 
3. If Needed, Parties Begin Meet and 
Confer Process  Regarding Scope of 
Initial Document Requests 
Within 14-days following the 
Court’s ruling on Defendant’s 
Motion to Dismiss  
Case 1:22-cv-01249-VMC     Document 15-1     Filed 06/29/22     Page 1 of 2

 
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4. If Needed, Parties File Joint 
Proposed ESI Protocol and 
Stipulated Protective Order 
Within 14-days following the 
Court’s ruling on Defendant’s 
Motion to Dismiss  
5. Beginning of Discovery pursuant to L.R. 
26.2(A) 
30 days after Defendant files 
answer 
6. Parties shall identify their initial experts 
and serve their initial expert written 
report(s) in accordance with F. R. Civ. P. 
26(a)(2)(B) 
Six months after the beginning of 
fact discovery  
7. Parties shall identify any rebuttal and/or 
reply expert written reports in accordance 
with F. R. Civ. P. 26(a)(2)(B) 
Forty-five (45) after initial expert 
report 
8.  Discovery Closes 
Eight months after beginning of  
fact discovery 
11. L.R. 16.3 Conference 
Two weeks after close of discovery 
12. Plaintiffs’ file Class Certification Motion 
along with Class Certification Expert 
Declarations in Support 
Six weeks after Rule 16.3 
Conference 
13. Defendant files any Opposition to 
Plaintiffs’ Class Certification  Motion along 
with any Expert Declarations in Support  
Forty-five (45) days after service of  
Plaintiffs’ motion 
14. Plaintiffs file any Reply in Support of 
Motion for Class Certification. [Plaintiffs 
may also file any Rebuttal Expert 
Declarations in Support.]  
Twenty-one (21) days after service 
of  Defendants’ opposition 
15. If Needed, Parties Meet and Confer and 
Propose a Case Schedule to the Court for 
Any Remaining Case Activities 
Within 14 days following the 
Court’s ruling on Plaintiff’s Motion 
for Class Certification 
 
 
 So ORDERED, this ____ day of July,  2022. 
 
 
 
 
 
 
 
________________________ 
Hon. Victoria M. Calvert 
United States District Judge 
Northern District of Georgia 
 
Case 1:22-cv-01249-VMC     Document 15-1     Filed 06/29/22     Page 2 of 2

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