RULE 26(f) DISCOVERY PLAN REPORT.Document filed by Visa Inc — United States v. Visa Inc. (Dkt. 94)

Summary

A [Proposed] Joint Amended Scheduling and Case Management Order submitted by the United States of America and Visa Inc. in Case No. 1:24-cv-07214-JGK-SLC, in the U.S. District Court for the Southern District of New York, stamped filed July 23, 2025 as Doc. 94. It states that it supersedes the Joint Amended Rule 26(f) Report and Case Management Plan and Scheduling Order of January 20, 2025. The case schedule lists close of fact discovery on March 17, 2026, close of expert discovery on August 7, 2026, and motions for summary judgment and Daubert motions filed September 4, 2026. Trial begins on a date to be determined by the Court. The signature blocks show /s/ Craig Conrath and /s/ Brian Stekloff.

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Full text

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UNITED STATES DISTRICT COURT 
FOR THE SOUTHERN DISTRICT OF NEW YORK 
 
UNITED STATES OF AMERICA, 
Plaintiff, 
v.  
VISA INC., 
Defendant. 
 
 
Case No. 1:24-cv-07214-JGK-SLC 
 
 
[PROPOSED] JOINT AMENDED SCHEDULING AND CASE MANAGEMENT ORDER 
Pursuant to Federal Rule of Civil Procedure (“FRCP”) 26(f), the United States of 
America (“Plaintiff”) and Visa Inc. (“Visa”) (together, the “Parties,” and individually a “Party”), 
have met and conferred on the topics outlined in this Joint Amended Scheduling and Case 
Management Order, which supersedes the Joint Amended Rule 26(f) Report and Case 
Management Plan and Scheduling Order of January 20, 2025, ECF No. 53. 
1. 
Nature of Claims and Defenses.  The Parties previously set forth their respective 
statements on the nature of the claims and defenses in this matter in the January 20, 2025 
Scheduling Order, ECF No. 53. 
2. 
Initial Disclosures.  The Parties exchanged the initial disclosures required under 
FRCP 26(a)(1) on January 13, 2025. 
3. 
Consent to Proceed before a Magistrate Judge.  The Parties do not consent to 
trial being conducted by a Magistrate Judge. 
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4. 
Alternative Dispute Resolution.  Pursuant to Local Rule 83.9(d), the Parties 
have considered the use of alternative dispute resolution, but at this time do not believe that 
mediation or a judicial settlement conference would facilitate the resolution of this matter. 
5. 
Protective Order.  The Parties agreed on the terms of an Amended Stipulated 
Protective Order (“Protective Order”), which the Court entered on June 4, 2025, ECF No. 84. 
6. 
Preservation and Production of Electronically Stored Information (“ESI”).  
The Parties entered into a stipulated order governing ESI discovery, which was entered by the 
Court on March 18, 2025, ECF No. 66.  No deadline in this order shall override any deadline set 
forth in the Protective Order or ESI Order. 
7. 
Phases of Discovery.  To ensure a more trial-ready and efficient case, the Parties 
agreed to conduct discovery in this case in two phases: 
a. 
Phase I:  The first phase of discovery focused primarily on third-party discovery 
and commenced upon Visa’s filing of its motion to dismiss on February 7, 2025, 
and continued until the Court’s ruling on that motion on June 23, 2025.  In 
addition to third-party discovery, the Parties also exchanged a limited set of 
agreed upon materials, as outlined in the January 20, 2025 Scheduling Order, ECF 
No. 53. 
b. 
Phase II:  The second phase of discovery began immediately following the 
Court’s decision on Visa’s motion to dismiss.  The second phase will encompass 
any remaining third-party discovery, as well as additional Party discovery, as 
agreed upon in the below Case Schedule. 
c. 
Furthermore, the Parties are continuing to discuss the need for coordination of 
discovery with the private follow-on actions, In re Visa Debit Antitrust Litigation, 
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1:24-cv-07435-JGK (S.D.N.Y) (the “Private Actions”), (should the Private 
Actions proceed past the motion to dismiss phase).  The Parties plan to continue 
these discussions—including with the plaintiffs in the Private Actions (“Private 
Plaintiffs”)—and will update the Court as needed. 
8. 
Case Schedule.  Pursuant to the Court’s Order, the following case schedule shall 
govern this Action:1 
Event 
Deadline 
Deadline to amend pleadings or join parties without leave of 
court
July 24, 2025 
Interim Fact discovery deadlines2 
 Parties to exchange preliminary fact witness lists
November 1, 2025 
 Parties to exchange updated preliminary fact witness 
lists
January 20, 2026 
Close of fact discovery
March 17, 2026
Plaintiff to identify expert witnesses and topics for each expert
March 17, 2026
Visa to identify expert witnesses and topics for each expert
April 17, 2026
Plaintiff to serve initial expert report(s)
May 1, 2026
Plaintiff to identify reply experts and topics for each expert
May 15, 2026
Defendant to serve rebuttal expert report(s)
June 17, 2026
Plaintiff to serve reply expert report(s)
July 17, 2026
Close of expert discovery
August 7, 2026 
Motions for summary judgment and Daubert motions filed
September 4, 2026
Oppositions to motions for summary judgment and Daubert 
motions filed
October 5, 2026 
Replies concerning motions for summary judgment or Daubert 
motions filed
October 19, 2026 
Parties to reach agreement and propose to the Court a protocol 
regarding confidentiality of materials to be used at trial, 
including non-party documents 
12 weeks before trial 
Parties exchange initial exhibit lists, and opening deposition 
designations
12 weeks before trial 
Each side exchanges its objections to the other side’s exhibits 
and deposition designations and its deposition counter-
designations
8 weeks before trial 
 
1 Unless otherwise specified, days will be computed according to FRCP 6(a). 
2 Interim discovery deadlines may be extended by written consent of the Parties without 
application to the Court, provided that all fact discovery is completed by March 17, 2026. 
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Parties exchange final witness lists
8 weeks before trial
Parties exchange final exhibit lists
6 weeks before trial
Motions in limine filed
6 weeks before trial
Each side exchanges its objections to the other side’s deposition 
counter-designations and its counter-counter-designations
5 weeks before trial 
Oppositions to motions in limine filed
4 weeks before trial.  
Joint Pretrial Order Deadline
4 weeks before trial
Pre-trial briefs filed
3 weeks before trial
Proposed findings of fact and conclusions of law filed  
3 weeks before trial
Hearing regarding any disputes raised in pre-trial submissions 
by Parties and non-parties, including motions in limine
2 weeks before trial 
Final pre-trial conference 
2 weeks before trial
Trial begins
Date to be determined by Court
 
9. 
Data Productions.   The Parties are negotiating the specific data to be produced 
in this case as part of discovery, including appropriate deadlines for production.  However, to 
date, the Parties have been unable to reach agreement.  The Parties will continue to negotiate and 
update the Court by August 13, 2025 as to the status of those conversations.   
10. 
Witness Lists and Deposition Designations.   
a. Preliminary Fact Witness List. Each side shall provide a preliminary fact 
witness list on or before the date specified in the case schedule. No more 
than a total of 40 fact witnesses whom the Party intends to present live at 
trial may be included on the preliminary witness list.  With respect to non-
parties for which depositions are not complete, such non-parties can be 
identified in a corporate capacity on the preliminary fact witness list, but 
only if at the time the preliminary list is due the Party naming the non-
party witness in good faith lacks knowledge of the individual identity of 
the witness. 
b. Updated Preliminary Fact Witness List.  Each side shall provide an 
updated preliminary fact witness list on or before the date specified in the 
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case schedule.  No more than a total of 40 fact witnesses may be included 
on the updated preliminary fact witness list.  No more than 10 of these 
witnesses may be substitutions or additions to those listed on the 
preliminary fact witness list (excluding witnesses previously identified 
only in a corporate capacity).  The witnesses on the updated preliminary 
fact witness list must be individually identified by name and not in a 
corporate capacity.  To the extent, however, depositions of a non-party 
noticed pursuant to Rule 30(b)(6) are scheduled after the date specified for 
exchange of the updated preliminary fact witness list, a Party may 
continue to identify any witness associated with that corporate entity in a 
corporate capacity, but will update the preliminary fact witness list to 
identify that witness by name within 7 days after any such deposition. 
c. Final Witness Lists. Each side shall provide a final witness list 8 weeks 
before trial, which shall be limited to those witnesses previously included 
on the Party’s updated preliminary witness list, absent good cause or 
agreement of the Parties, and to no more than 30 persons, excluding 
experts.  The Parties agree that it shall constitute good cause to modify the 
final witness list to replace or remove a witness if that witness departs 
from the company that employed the witness at the time of their 
deposition.  The Parties have been unable to reach agreement regarding 
each side’s entitlement to discovery and depositions of any new fact 
witnesses who are added to a final trial witness list who were not 
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previously identified on the Parties’ updated preliminary witness lists.  The 
Parties’ respective positions are as follows: 
i. United States’ Position:  The United States proposes that if any 
newly identified fact witnesses are added to the Parties’ final 
witness lists, document discovery and depositions should be had 
with respect to such person(s), even if out of time.  The United 
States further proposes that any document discovery and/or 
deposition notices of new witnesses on the Parties’ final witness 
lists must be issued within 7 days of service of the final witness 
lists.  Defendant’s alternative proposal—that the Parties agree only 
to negotiate in good faith—is inadequate and does not ensure that 
witnesses who are identified for the first time within mere weeks 
of trial get deposed and their custodial documents provided to the 
other side. 
ii. Visa’s Position: Visa believes it is premature to authorize discovery 
after the close of fact discovery.  Should there come a time when 
the needs of the case and the specific circumstances merit 
additional post-deadline discovery, Visa will negotiate the contours 
of such discovery in good faith.  There are any number of reasons 
though that additional discovery might not be appropriate, and a 
blanket authorization for such discovery at this time would not 
further judicial economy.   
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d. Deposition Designations. Witnesses whose testimony will be offered into 
evidence at trial through designated portions of their deposition testimony 
shall be identified on final trial witness lists, however those witnesses do 
not count against the limits on the numbers of persons who may be 
identified on those lists. 
e. General Principles for Witness Lists. In preparing preliminary fact 
witness lists and final witness lists, the Parties must make good-faith 
attempts based on information reasonably available to them at that time to 
identify the witnesses whom they expect that they will present as live 
witnesses at trial (other than solely for impeachment). The witness lists 
must include contact information for known counsel or, if no counsel is 
known, the name, employer, address, and telephone number of each 
witness (if known). No Party may call a person to testify as a live witness 
at trial (other than solely for impeachment) unless (a) that person was 
identified on that Party’s final trial witness list; (b) all Parties agree that 
that Party may call that person to testify; or (c) ordered by the Court after 
that Party demonstrates good cause for allowing it to call that person to 
testify, despite that Party’s failure to identify that person sooner.  
11. 
Timely Service of Fact Discovery and Supplemental Discovery.  All discovery, 
including discovery served on non-parties, must be served in time to permit completion of 
responses by the close of fact discovery. 
12. 
Interrogatories.  Pursuant to the Court’s order on January 20, 2025, ECF No. 53, 
each side is limited to 25 interrogatories. 
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13. 
Requests for Admission.  Each side is limited to 35 requests for admission in 
total.  Each request may include subparts that relate directly to the subject matter of the request 
(e.g., date, time and author of a document or series of emails; multiple dates of an employee’s 
positions in a company).  Each side reserves the right to ask the Court for leave to serve 
additional requests for admission. 
14. 
Depositions.  Pursuant to the Court’s order on January 20, 2025, ECF No. 53, 
each side is limited to a total of 350 hours of deposition time on the record of fact witnesses.  
Each side may use a maximum of 225 hours of such deposition time on the record in deposing 
adverse Party witnesses.  Unless the Parties otherwise agree or the Court grants leave on a 
Party’s motion, each side may serve one notice pursuant to FRCP 30(b)(6) on the opposing side.  
The 30(b)(6) notice may call for testimony on multiple subjects and the responding Party may 
designate one or more different witnesses as to each subject matter.  The Parties also agree to the 
following regarding depositions: 
a. Calculation of Time.  Reasonable breaks will be excluded from calculation 
of deposition time under Rule 30(d)(l) of the Federal Rules of Civil 
Procedure. Only a reasonable amount of time for a deponent to review a 
document tendered for the examination will count against the Rule 
30(d)(l) limits. 
b. Corporate Representative Depositions.  The Parties will cooperate to 
determine whether a corporate representative or representatives will also 
be deposed in their individual capacities and make arrangements for the 
corporate representative and individual portions of the deposition for each 
representative to take place on the same day or on consecutive days.   
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c. Additional Time.  The Parties reserve the right to seek from the Court 
additional deposition time with particular witnesses or a different 
allocation of time than the allocations that are set forth within this Section. 
d. Cross-Noticed Depositions of Non-parties.  In the case of a non-party 
deposition noticed by both sides, each side may examine the witness for a 
maximum of 3.5 hours each, up to a maximum total of 7 hours on one day.  
The deposition of a former Party employee that is not represented by 
counsel for that Party shall be considered a non-party deposition for the 
purposes of this provision.  Each side may choose to examine 7 non-party 
witnesses for a maximum of 7 hours each, up to a total of 14 hours if both 
Parties so choose.  In the case of a cross-noticed deposition that will 
extend beyond 7 hours, the witness may elect to have the deposition occur 
over one or two consecutive days.  A Party must serve a cross-notice of 
deposition on a non-party, if any, within 7 days of service of the original 
notice of deposition.  If either Party does not use their allocated maximum 
number of hours, the other Party may use any of the remaining time, to be 
counted towards its 350 hour limit.   
e. Exclusions from Deposition Limits.  The following depositions do not 
count against the proposed deposition limits: (a) depositions of the Parties’ 
designated expert witnesses; and (b) pre-Complaint depositions taken in 
response to Civil Investigative Demands.  Pursuant to the Court’s order on 
January 20, 2025, ECF No. 53, depositions taken for the sole purpose of 
establishing the location, authenticity, or admissibility of documents 
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produced by any Party or non-party shall count against the deposition 
limits set forth above. 
f. Witness Service.  Parties will use their best efforts to make witnesses available 
for deposition at a mutually agreeable time and location and without undue 
delay. If a witness is a former employee of any Party who is not represented by 
counsel, upon receipt of a deposition notice for the former employee, that Party 
shall, within 10 business days of the deposition notice, provide the date of 
departure and last known address of the former employee, whether the Party’s 
counsel can accept service of the notice, whether the Party’s counsel will be 
representing that Party in connection with the deposition and, if not, the name 
and contact information for the witness’s counsel or that the witness is 
unrepresented.  Where a witness is not reasonably available before the 
close of fact discovery, the Parties may, by mutual agreement, schedule a 
deposition after the close of fact discovery without having to seek leave of 
Court. 
g. Document or ESI Subpoena Service.  If a Party serves a subpoena for the 
production of documents or electronically stored information and a subpoena 
commanding attendance at a deposition, the Party serving those subpoenas 
must schedule the deposition for a date at least 14 days after the return date for 
the document subpoena.  If the production of documents or electronically 
stored information responsive to any subpoena served on a third party is 
delayed and are made available to any Party in less than 14 days of the 
deposition date for that third party, the date scheduled for the deposition must 
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be postponed to be at least 14 days following the actual production date, unless 
all Parties consent to fewer than 14 days. 
h. Depositions of Party Witnesses.  Consistent with Rule 30 of the Federal Rules 
of Civil Procedure, depositions of Party fact witnesses are limited to 7 hours on 
the record.    
i. Depositions of Expert Witnesses.  Each expert deposition will be limited to 7 
hours on the record.  The Parties disagree as to when experts may be 
deposed following disclosure of expert reports. The Parties’ respective 
positions are as follows:   
i. United States’ position:  The United States’ position is that the widely 
accepted standard practice of deposing each side’s expert once should 
prevail.  Defendant proposes requiring the plaintiff’s expert(s) (but not 
their own) to sit for two separate depositions—one after each report.  
Such a requirement would be both inefficient and, as illustrated by the 
very case Defendant cites as justification, inequitable.  See In re 
Chicago Bridge & Iron Co. N.V. Sec. Litig., 2019 WL 6879321, at 
*1–2 (S.D.N.Y. Dec. 16, 2019) (allowing defendants to depose 
plaintiffs’ expert twice notwithstanding “the default rule . . . that each 
witness may only be deposed once” but giving the same opportunity to 
plaintiffs citing “fundamental fairness”).  Moreover, every case on 
which the In re Chicago Bridge & Iron Co. court relied in support 
of its holding was one where the party seeking the second 
deposition had not previously had an opportunity to depose the 
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other side’s expert about a supplemental or rebuttal report or 
because the expert introduced new opinions or analysis into a 
subsequent report after the first deposition had already taken 
place.  See also Cmty. Assoc. Underwriters of Am., Inc. v. Rauscher 
Horticultural, LLC, 2022 WL 1793190, at *2 (W.D.N.Y. June 2, 
2022) (characterizing In re Chicago Bridge & Iron Co. as an 
example of a case in which an opposing party is “entitled to a 
second deposition where a supplemental report is served in order to 
explore new opinions . . .”).  Such is not the case here, as under the 
proposed schedule, all parties will have received all expert reports 
before any expert depositions are taken.  As justification for its 
contrary position, Defendant asserts that the three-week period from 
July 17, 2026 until the close of expert discovery on August 7, 2026 is 
insufficient time for expert depositions to take place.  Plaintiff 
disagrees, but in order to address this concern, the United States offered 
to extend the period of expert discovery by an additional 10 days to 
allow for a full month following service of reply expert report(s) until 
the close of expert discovery.  The United States believes that the 
parties are capable of taking depositions within the three-week period 
originally agreed to in the January 20, 2025 CMO, but is amenable to a 
reasonable extension to allow for additional time if necessary, so long 
as it does not unreasonably extend later deadlines in the case schedule. 
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ii. Visa’s position: The Parties should make their expert witnesses 
available for deposition after each report offered by that expert and 
should do so reasonably in advance of any deadline for responsive 
reports, where applicable.  This process would allow each side’s expert 
the opportunity to review the deposition transcript prior to submitting a 
responding report and will greatly streamline later reports by ensuring 
that such reports are responsive to the arguments and analyses on 
which the Parties intend to rely and not, for example, built upon a 
misunderstanding of that analysis or a failure to address errors or 
omissions that may come to light only later during depositions.  See, 
e.g., In re Dynamic Random Access Memory (DRAM) Antitrust Litig., 
2006 WL 3462580, at *1 (N.D. Cal. Nov. 29, 2006) (holding schedule 
permitted defendants to depose plaintiffs’ experts after both opening 
and reply reports where plaintiffs suffered no burden given schedule 
also allowed plaintiffs to depose defendants’ experts before plaintiffs 
prepared a rebuttal report); In re Chicago Bridge & Iron Co. N.V. 
Sec. Litig., 2019 WL 6879321, at *1–2 (S.D.N.Y. Dec. 16, 2019) 
(collecting cases where courts have allowed depositions after each 
report).  Plaintiff’s response that this is inequitable because only 
their experts would be subject to multiple depositions is not well-
taken.  Visa has agreed to permit staggered expert reports such that 
only the government will get rebuttal reports and thus will have the 
final say.  In exchange for that benefit, it is not prejudicial to 
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require their experts to be deposed on each report submitted.  
Further, Plaintiff’s proposal is untenable and unfairly prejudicial 
because it limits all expert depositions, including regarding the 
government’s reply reports, to a brief three-week period immediately 
following the filing of reply reports.  As Visa has previously indicated, 
the expert schedule may be tight.  Indeed, during that brief window, 
Visa’s experts would be tasked with both assisting Visa in the review of 
the government’s reply reports for purposes of preparing for 
depositions of the government’s experts, while simultaneously trying to 
prepare for and defend their own deposition.  Meanwhile, the 
government will have had an additional month to consider and respond 
to Visa’s experts and prepare for depositions and will be able to focus 
solely on defending their own reports during that brief period.  To 
address these concerns, Plaintiff suggests the Parties extend the end of 
expert discovery, but no other deadlines, by 10 days.  That proposal 
should be rejected as it prejudicially reduces the already limited time 
that Visa will have to prepare summary judgment and Daubert 
motions.  
j. Remote Depositions.  The Parties agree to address separately any protocol for 
conducting depositions that may occur remotely and will submit a proposal no 
later than August 29, 2025.   
15. 
Discovery Dispute Resolution.  In the event of a dispute between the Parties 
and/or a non-party regarding any discovery issue, the Parties (and the non-party when applicable) 
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shall meet and confer in an attempt to resolve the dispute. In the event of a dispute during a 
deposition, the Parties and/or non-parties shall memorialize the dispute on the record and present 
the dispute to the Court by motion within 7 business days of the close of the deposition. If the 
Court orders a Party or non-party to provide additional testimony (i.e., rejects the opposition of 
the Party or non-party to answering a particular question), the Party or non-party shall provide 
the witness for deposition on the testimony in question within 10 business days of the ruling. 
16. 
Demonstrative Exhibits.  Demonstrative exhibits do not need to be included on 
the trial exhibit lists when those lists are exchanged.   
17. 
Word Limits on Pre-trial Briefs. The Parties agree that word-count limits are 
appropriate for both the Pre-Trial Briefs and the Proposed Findings of Fact and Conclusions of 
Law, and agree to suggest specific word-count limits to the Court after the close of discovery and 
after any summary judgment motions have been resolved. 
18. 
Nationwide Service of Trial Subpoenas. To assist the Parties in planning 
discovery, and in view of the geographic dispersion of potential witnesses in this action outside 
this District, the Parties are permitted, under 15 U.S.C. § 23, to issue nationwide discovery and 
trial subpoenas from this Court. The availability of nationwide service of process, however, does 
not make a witness who is otherwise “unavailable” for purposes of Federal Rule of Civil 
Procedure 32 and Federal Rule of Evidence 804 available under those rules or otherwise affect 
the admissibility at trial of a deposition of a witness. 
19. 
Modification of Scheduling and Case Management Order.  Any Party may 
seek modification of this Order for good cause. 
* * * 
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The Parties appreciate the Court’s consideration of this proposed order and would be 
happy to discuss their positions at a hearing to assist the Court’s resolution of any disputed 
issues. 
 
DATED: July 23, 2025 
By:      /s/ Craig Conrath 
Craig Conrath 
Christopher Jackson 
Bennett J. Matelson 
Michele Trichler 
United States Department of Justice 
Antitrust Division 
450 Fifth Street, N.W., Suite 4000 
Telephone: (202) 894-4266 
Facsimile: (202) 514-7308 
Craig.Conrath@usdoj.gov  
Christopher.Jackson5@usdoj.gov 
Bennett.Matelson@usdoj.gov 
Michele.Trichler@usdoj.gov 
 
Counsel for Plaintiff, the United States 
  
Respectfully submitted, 
By:      /s/ Brian Stekloff 
Beth Wilkinson (SBN NY 2181592) 
Brian Stekloff (admitted pro hac vice) 
Kieran Gostin (SBN NY 4847653) 
Roxana Guidero (admitted pro hac vice) 
WILKINSON STEKLOFF LLP 
2001 M Street NW, 10th floor 
Washington, DC 20036 
Telephone: (202) 847-4000 
Facsimile: (202) 847-4005 
bwilkinson@wilkinsonstekloff.com 
bstekloff@wilkinsonstekloff.com 
kgostin@wilkinsonstekloff.com 
rguidero@wilkinsonstekloff.com 
 
Jeremy Barber (SBN NY 5344304) 
Anthony P. Ferrara (SBN NY 5656905)  
WILKINSON STEKLOFF LLP 
130 W 42nd Street, Floor 24 
New York, NY 10036 
 (212) 294 8910 
jbarber@wilkinsonstekloff.com 
aferrara@wilkinsonstekloff.com 
 
Anne P. Davis (admitted pro hac vice)  
Jonathan Ian Gleklen (admitted pro hac 
vice)  
ARNOLD & PORTER KAYE 
SCHOLER LLP  
601 Massachusetts Avenue NW  
Washington, D.C. 20001 
Telephone: (202) 942-6197
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Facsimile: (202) 942-5999 
anne.davis@arnoldporter.com 
jonathan.gleklen@arnoldporter.com 
 
Counsel for Defendant Visa, Inc. 
 
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