Exhibit 1: [Proposed] Scheduling Order, The Federal Securities Tranche (Document 515-1)
Summary
Exhibit 1 to Document 515 in Case 1:21-md-02989-CMA (Document 515-1), entered on the FLSD docket 10/07/2022, is a [Proposed] Scheduling Order for the Federal Securities Tranche of In re: January 2021 Short Squeeze Trading Litigation, Case No. 21-2989-MDL-ALTONAGA/Torres, which would assign the case to a complex case management track allowing 12 months of fact discovery from the date of the scheduling order. The proposed schedule sets November 17, 2022 for Plaintiffs to identify additional class representatives, January 13, 2023 for the motion for class certification, April 13, 2023 for Defendants' opposition and October 18, 2023 for the close of fact discovery including depositions. Later dates run to June 17, 2024 for filing all summary judgment and Daubert motions, with proposed opposition and reply dates of September 17, 2024 and November 1, 2024.
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- Gov.Uscourts.Flsd.590042.515.1
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Cite this document
“Exhibit 1: [Proposed] Scheduling Order, The Federal Securities Tranche (Document 515-1).”
Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-flsd-590042-515-1/
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Case 1:21-md-02989-CMA Document 515-1 Entered on FLSD Docket 10/07/2022 Page 1 of 5
Exhibit 1
Case 1:21-md-02989-CMA Document 515-1 Entered on FLSD Docket 10/07/2022 Page 2 of 5
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 21-2989-MDL-ALTONAGA/Torres
IN RE:
JANUARY 2021 SHORT SQUEEZE
TRADING LITIGATION
_______________________________/
This Document Relates to:
The Federal Securities Tranche
[PROPOSED] SCHEDULING ORDER
Pursuant to Rule 16(b) of the Federal Rules of Civil Procedure, Local Rule 16.1(b)(3) of the
Local Rules of the United States District Court for the Southern District of Florida, upon consideration
of the Joint Planning and Scheduling Report filed by the parties in the above-styled matter, and this
Court being otherwise fully advised in the premises, it is:
ORDERED AND ADJUDGED as follows:
A. Track:
This case shall be assigned to a complex case management track that allows for 12 months of fact
discovery from the date of the scheduling order.
Case 1:21-md-02989-CMA Document 515-1 Entered on FLSD Docket 10/07/2022 Page 3 of 5
B. The parties shall adhere to the following schedule:
November 17, 2022
Plaintiffs to identify additional class representatives for Class
(30 Days from the Date of
Certification
this Order)
Deadline to join additional defendants or to file motion to amend
February 15, 2023 (120 Days
pleadings.
from the Date of This Order)
The parties shall select a mediator pursuant to Local Rule 16.2, shall
schedule a time, date and place for mediation, and shall jointly file a
proposed order scheduling mediation in the form specified on the
Court’s website, http://www.flsd.uscourts.gov. If the parties cannot
agree on a mediator, the Clerk shall designate a certified mediator on December 19, 2022
a blind rotation basis. Counsel for all parties shall familiarize (60 Days From the Date of
themselves with and adhere to all provisions of Local Rule 16.2. This Order)
Within seven (7) days of mediation, the parties are required to file a
mediation report with the Court. Pursuant to the procedures outlined
in the CM/ECF Administrative Procedures, the proposed order must
be emailed to altonaga@flsd.uscourts.gov in Word format.
January 13, 2023
Plaintiffs shall file a motion for class certification (including any
opening class certification expert report(s)).
March 29, 2023
Defendants shall complete the depositions of all proposed class (75 days after Motion for
representatives and plaintiffs’ class certification experts Class Certification is
Filed)
April 13, 2023
Defendants shall file opposition to class certification (including any
(90 days after Motion for
opposing expert witness reports)and any Daubert motions related to
Class Certification is
expert witnesses on issues of class certification..
Filed)
Parties shall fully complete production of documents. Parties agree to April 18, 2023
commence producing documents on a rolling basis as much as is (Six Months From the
possible in advance of this deadline. Date of this Order)
Plaintiffs shall file reply brief in support of motion for class May 30, 2023
certification, rebuttal expert reports, Daubert motions relating to (45 days after class
Defendants’ class certifications expert reports, and any opposition to certification opposition
Defendants' class certification Daubert motions papers filed)
June 29, 2023
Defendants’ shall file any replies in support of Daubert motions
(30 days after Plaintiffs’
relating to class certification.
Opposition is Filed)
Plaintiffs shall file any replies in support of their Daubert motions July 1, 2023
relating to class certification. (30 days after
Defendants’ Opposition is
Filed)
August 14, 2023
Parties must have completed mediation and filed a mediation report. (300 Days From the Date
of This Order)
October 18, 2023
Close of fact discovery including depositions. (12 Months From Date of
This Order)
Case 1:21-md-02989-CMA Document 515-1 Entered on FLSD Docket 10/07/2022 Page 4 of 5
December 18, 2024
Plaintiffs shall provide expert witness disclosures as required by Fed.
(60 Days from the Close of
R. Civ. P. 26(a)(2)(A)-(C).
Fact Discovery)
February 16, 2024
Defendants shall provide expert witness disclosures as required by (60 Days After Plaintiff
Fed. R. Civ. P. 26(a)(2)(A)-(C). Expert Reports)
April 1, 2024 (45 Days After
Plaintiffs shall provide rebuttal expert reports,
Defendants’ Expert Reports)
All discovery, including expert depositions, is completed. April 16, 2024
Depositions of expert witnesses shall not commence until after (60 Days After Defendant
Plaintiffs provide rebuttal expert reports, if any. Expert Reports)
All summary judgment and Daubert motions (which include motions
to strike experts) are filed. Each motion shall be governed by Local
Rule 7.1. Leave to exceed the 20-page limit in Local Rule 7.1(c) will
be granted if the issues addressed in either the summary judgment
motion or any Daubert motions cannot be addressed within those
June 17, 2024
page limits. The parties are reminded that Daubert motions must
(60 Days After Close of All
contain the Local Rule 7.1(a)(3) certification.
Discovery)
The parties further propose that all oppositions to summary judgment
motions and Daubert motions be due 60 days after such motions are
filed (September 17, 2024) and replies be due 45 days after
opposition (November 1, 2024).
60 Days After a Decision is
Parties submit joint pre-trial stipulation, proposed jury instructions
Rendered on Dispositive
and verdict form, or proposed findings of fact and conclusions of law,
Motions Including Summary
as applicable.
Judgment
Motions in limine directed to trial evidence due. The parties are
14 Days Before
reminded that motions in limine must contain the Local Rule 7.1(a)(3)
Commencement of Trial.
certification.
Case 1:21-md-02989-CMA Document 515-1 Entered on FLSD Docket 10/07/2022 Page 5 of 5
IT IS FURTHER ORDERED as follows:
Pretrial motions will be resolved, to the extent feasible, within days of the close of
fact discovery. The pretrial conference will be held at , on .
Trial will begin at , on .
DONE AND ORDERED in Chambers, at Miami-Dade County, Florida, this _____ day
of ___________________, 2022.
______________________________________
CECILIA M. ALTONAGA
UNITED STATES DISTRICT JUDGE
4
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