Scheduling Order — Together Employees v. Mass General Brigham Incorporated (Dkt. 56)

Summary

A Scheduling Order, Document 56, filed December 17, 2021 in Together Employees, by individual representatives, et al. v. Mass General Brigham Incorporated, Civil Action No. 21-11686-FDS, in the United States District Court, District of Massachusetts. Under Rule 16(b) of the Federal Rules of Civil Procedure and Local Rule 16.1(F), it orders initial disclosures completed by March 1, 2022, a response to the complaint by January 22, 2022, and written discovery served no later than March 16, 2022. It sets completion of Phase 1 depositions by September 1, 2022 and dispositive motions to be filed by February 15, 2023, with oppositions within 21 days after service. The order ends with "By the Court" and /s/ Matthew McKillop, Deputy Clerk.

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“Scheduling Order — Together Employees v. Mass General Brigham Incorporated (Dkt. 56).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-mad-238919-56-0-28abeaf792/, SHA-256 78176f89bd4978754727d3a852dcbbfed4c7eef3338f37bc9a13ccc87218aac8.

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Case 1:21-cv-11686-FDS Document 56 Filed 12/17/21 Page 1 of 4

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

_______________________________________
)
TOGETHER EMPLOYEES, by )
individual representatives, ROBERTA )
LANCIONE, JOYCE MILLER, MARIA )
DIFRONZO, MICHAEL SACCOCCIO, )
ELIZABETH BIGGER, NATASHA )
DICICCO, NICHOLAS ARNO, and )
RUBEN ALMEIDA, )
) Civil Action No.
Plaintiffs, ) 21-11686-FDS
)
v. )
)
MASS GENERAL BRIGHAM )
INCORPORATED, )
)
Defendant. )
_______________________________________)

SCHEDULING ORDER
SAYLOR, C.J.

This Scheduling Order is intended to provide a reasonable timetable for discovery and
motion practice in order to help ensure a fair and just resolution of this matter without undue
expense or delay.

Timetable for Discovery and Motion Practice

Pursuant to Rule 16(b) of the Federal Rules of Civil Procedure and Local Rule 16.1(F), it
is hereby ORDERED as follows:

1. Initial Disclosures. Initial disclosures required by Fed. R. Civ. P. 26(a)(1) must
be completed by March 1, 2022.

2. Amendments to Pleadings. Except for good cause shown, no motions seeking
leave to add new parties or to amend the pleadings to assert new claims or
defenses may be filed after December 17, 2021.

3. Response to Complaint. Defendant must answer, move, or otherwise respond to
plaintiffs’ complaint by January 22, 2022.
Case 1:21-cv-11686-FDS Document 56 Filed 12/17/21 Page 2 of 4

4. Fact Discovery – Phase 1.
a. Written discovery (requests for production of documents, interrogatories,
and requests for admissions) shall be served no later than March 16, 2022.

b. All depositions, other than expert depositions, must be completed by
September 1, 2022.

i. Plaintiffs, without leave of the Court, may take 10 depositions
during Phase 1.

ii. Defendant may take up to 30 depositions of plaintiffs (up to 15
selected by plaintiffs and up to 15 selected by defendant) during
Phase 1.

c. Phase 1 of fact discovery will close on September 1, 2022.

5. Fact Discovery – Phase 2.
a. The Court will set fact discovery deadlines for Phase 2 at a later date.

6. Fact Discovery – Final Deadline.
a. The Court will set a final deadline for fact discovery at a later date.

7. Status Conferences. Status conferences will be held on January 19, 2022, at 3:00
p.m., and February 25, 2022, at 3:00 p.m.

8. Expert Discovery.
a. The Court will set a timetable for expert discovery at a later date.

9. Dispositive Motions.
a. Dispositive motions, such as motions for summary judgment or partial
summary judgment and motions for judgment on the pleadings, must be
filed by February 15, 2023.

b. Oppositions to dispositive motions must be filed within 21 days after
service of the motion.

c. If appropriate, any deadlines for subsequent dispositive motions will be set
at a later date.

10. Initial and Pretrial Conferences. The initial pretrial conference will be
scheduled at a later point in the proceedings. The parties must prepare and submit
a pretrial memorandum in accordance with Local Rule 16.5(d) five business days
prior to the date of the conference, except that the parties need not include matters
required by Local Rule 16.5(d)(2) or (3). The trial date will normally be set at the
initial pretrial conference. A final pretrial conference will be scheduled at the
time the trial date is set. The court may also schedule interim pretrial conferences

2
Case 1:21-cv-11686-FDS Document 56 Filed 12/17/21 Page 3 of 4

in appropriate cases.

Procedural Provisions

1. Extension of Deadlines. Motions to extend or modify deadlines will be granted
only for good cause shown. All motions to extend shall contain a brief statement
of the reasons for the request; a summary of the discovery, if any, that remains to
be taken; and a specific date when the requesting party expects to complete the
additional discovery, join other parties, amend the pleadings, or file a motion.

2. Motions to Compel or Prevent Discovery. Except for good cause shown,
motions to compel discovery, motions for protective orders, motions to quash,
motions to strike discovery responses, and similar motions must be filed no later
than the close of fact discovery or the close of expert discovery, whichever
deadline is relevant. If additional discovery is compelled by the court after the
relevant deadline has passed, the court may enter such additional orders relating
to discovery as may be appropriate.

3. Reply Memoranda. Parties need not seek leave of court to file a reply
memorandum in response to an opposition to any motion, provided that such a
reply memorandum does not exceed twelve pages, double-spaced, and is filed
within seven days (excluding intermediate Saturdays, Sundays, and legal
holidays) after service of the opposition memorandum. Parties may otherwise file
reply or surreply memoranda only with leave of court. When such leave is
sought, the moving party may file a proposed reply or surreply memorandum with
the motion for leave.

4. Status Conferences. The court has scheduled a status conference after (or close
to) the close of fact discovery for case management purposes. Any party who
reasonably believes that a status conference will assist in the management or
resolution of the case may request one from the court upon reasonable notice to
opposing counsel.

5. Additional Conferences. Upon request of counsel, or at the court’s own
initiative, additional case-management or status conferences may be scheduled.
Parties may request telephonic conferences where appropriate to avoid undue
inconvenience or expense.

6. Early Resolution of Issues. The court recognizes that, in some cases, resolution
of one or more preliminary issues may remove a significant impediment to
settlement or otherwise expedite resolution of the case. Counsel are encouraged
to identify any such issues and to make appropriate motions at an early stage in
the litigation.

7. Attendance of Lead Counsel at Pretrial Conferences. Lead trial counsel are

3
Case 1:21-cv-11686-FDS Document 56 Filed 12/17/21 Page 4 of 4

required to attend the initial and final pretrial conferences, and any interim pretrial
conferences scheduled by the court. Other conferences may be handled by any
counsel who is appropriately prepared.

By the Court,

/s/ Matthew McKillop
Dated: December 17, 2021 Deputy Clerk

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