Revised Form D—For cases assigned to Judge Rakoff Effective September 10, 2010
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - x
`Gray
`Plaintiff(s),
`-v-
`Paramount
`Defendant(s).
`- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - x
`CIVIL CASE MANAGEMENT PLAN
`(JUDGE RAKOFF)
`25cv3484 (JSR)
`This Court requires that this case shall be ready for trial on
`10/9/2025.
`After consultation with counsel for the parties, the following Case Management Plan is adopted.
`This plan is also a scheduling order pursuant to Rules 16 and 26(f) of the Federal Rules of Civil Procedure.
`A. The case (is) (is not) to be tried to a jury. [Circle as appropriate]
`B. Joinder of additional parties must be accomplished by ____________________.
`C. Amended pleadings may be filed without leave of Court until ____________________.
`D. Discovery (in addition to the disclosures required by Fed. R. Civ. P. 26(a)):
`1. Documents. First request for production of documents, if any, must be served by
`____________________. Further document requests may be served as required, but no document
`request may be served later than 30 days prior to the date of the close of discovery as set forth in item
`6 below.
`2. Interrogatories. Interrogatories pursuant to Rule 33.3(a) of the Local Civil Rules of the Southern
`District of New York must be served by ____________________. No other interrogatories are
`permitted except upon prior express permission of Judge Rakoff. No Rule 33.3(a) interrogatories
`need be served with respect to disclosures automatically required by Fed. R. Civ. P. 26(a).
`3. Experts. Every party-proponent of a claim (including any counterclaim, cross-claim, or third-
`party claim) that intends to offer expert testimony in respect of such claim must make the disclosures
`required by Fed. R. Civ. P. 26(a)(2) by ____________________. Every party-opponent of such
`claim that intends to offer expert testimony in opposition to such claim must make the disclosures
`required by Fed. R. Civ. P. 26(a)(2) by ____________________. No expert testimony (whether
`designated as “rebuttal” or otherwise) will be permitted by other experts or beyond the scope of the
`opinions covered by the aforesaid disclosures except upon prior express permission of the Court,
`application for which must be made no later than 10 days after the date specified in the immediately
`preceding sentence. All experts may be deposed, but such depositions must occur within the time
`limit for all depositions set forth below.
`
`May 30, 2025
`May 30, 2025
`May 23, 2025
`May 23, 2025
`June 6, 2025
`July 3, 2025
`Liability Phase
`Case 1:25-cv-03484-JSR Document 13 Filed 05/09/25 Page 1 of 4
`
`
`
`
`
`
`
`4. Depositions. All depositions (including any expert depositions, see item 3 above) must be
`completed by ____________________. Unless counsel agree otherwise or the Court so orders,
`depositions shall not commence until all parties have completed the initial disclosures required by
`Fed. R. Civ. P. 26(a)(1) or until four weeks from the date of this Order, whichever is earlier.
`Depositions shall proceed concurrently, with no party having priority, and no deposition shall extend
`beyond one business day without prior leave of the Court.
`5. Requests to Admit. Requests to Admit, if any, must be served by ____________________
`[insert date that is no later than 30 days prior to date of close of discovery as set forth in item 6
`below].
`6. All discovery is to be completed by ____________________. Interim deadlines for items 1–5
`above may be extended by the parties on consent without application to the Court, provided the
`parties are certain they can still meet the discovery completion date set forth in this paragraph. The
`discovery completion date may be adjourned only upon a showing to the Court of extraordinary
`circumstances, and may not be extended on consent.
`E. Post-discovery summary judgment motions in the form prescribed by the Court’s Individual Rules of
`Practice may be brought on without further consultation with the Court provided that a Notice of any such
`motion, in the form specified in the Court’s Individual Rules of Practice, is filed no later than one week
`following the close-of-discovery date (item D-6 above) and provided that the moving papers are served by
`____________________, answering papers by ____________________, and reply papers by
`____________________ [the last of these days being no later than six weeks following the close of
`discovery]. Each party must file its respective papers with the Clerk of the Court on the same date that such
`papers are served. Additionally, on the same date that any papers are served and filed, counsel filing and
`serving the papers must arrange to deliver courtesy non-electronic hard copies to the Courthouse for delivery
`to Chambers.
`F. A final pre-trial conference, as well as oral argument on any post-discovery summary judgment
`motions, shall be held on ____________________ [date to be inserted by the Court], at which time the
`Court shall set a firm trial date. The timing and other requirements for the Joint Pretrial Order and/or other
`pre-trial submissions shall be governed by the Court’s Individual Rules of Practice.
`G. All motions and applications shall be governed by Judge Rakoff’s Individual Rules of Practice.
`Counsel shall promptly familiarize themselves with all of the Court’s Individual Rules, as well as with the
`Local Rules for the United States District Court for the Southern District of New York.
`SO ORDERED.
`_____________________________
`JED S. RAKOFF
`U.S.D.J.
`DATED: New York, New York
`___________________________.
`June 20, 2025
`July 25, 2025
`July 25, 2025
`August 1, 2025
`August 15, 2025
`August 22, 2025
`August 29, 2025
`Case 1:25-cv-03484-JSR Document 13 Filed 05/09/25 Page 2 of 4
`
`
`
`
`
`
`
`Revised Form D—For cases assigned to Judge Rakoff Effective September 10, 2010
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - x
`Gray
`Plaintiff(s),
`-v-
`Paramount
`Defendant(s).
`- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - x
`CIVIL CASE MANAGEMENT PLAN
`(JUDGE RAKOFF)
`25cv3484 (JSR)
`This Court requires that this case shall be ready for trial on
`10/9/2025.
`After consultation with counsel for the parties, the following Case Management Plan is adopted.
`This plan is also a scheduling order pursuant to Rules 16 and 26(f) of the Federal Rules of Civil Procedure.
`A. The case (is) (is not) to be tried to a jury. [Circle as appropriate]
`B. Joinder of additional parties must be accomplished by ____________________.
`C. Amended pleadings may be filed without leave of Court until ____________________.
`D. Discovery (in addition to the disclosures required by Fed. R. Civ. P. 26(a)):
`1. Documents. First request for production of documents, if any, must be served by
`____________________. Further document requests may be served as required, but no document
`request may be served later than 30 days prior to the date of the close of discovery as set forth in item
`6 below.
`2. Interrogatories. Interrogatories pursuant to Rule 33.3(a) of the Local Civil Rules of the Southern
`District of New York must be served by ____________________. No other interrogatories are
`permitted except upon prior express permission of Judge Rakoff. No Rule 33.3(a) interrogatories
`need be served with respect to disclosures automatically required by Fed. R. Civ. P. 26(a).
`3. Experts. Every party-proponent of a claim (including any counterclaim, cross-claim, or third-
`party claim) that intends to offer expert testimony in respect of such claim must make the disclosures
`required by Fed. R. Civ. P. 26(a)(2) by ____________________. Every party-opponent of such
`claim that intends to offer expert testimony in opposition to such claim must make the disclosures
`required by Fed. R. Civ. P. 26(a)(2) by ____________________. No expert testimony (whether
`designated as “rebuttal” or otherwise) will be permitted by other experts or beyond the scope of the
`opinions covered by the aforesaid disclosures except upon prior express permission of the Court,
`application for which must be made no later than 10 days after the date specified in the immediately
`preceding sentence. All experts may be deposed, but such depositions must occur within the time
`limit for all depositions set forth below.
`
`May 30, 2025
`May 30, 2025
`September 24, 2025
`September 24, 2025
`October 3, 2025
`October 20, 2025
`Damages Phase
`Case 1:25-cv-03484-JSR Document 13 Filed 05/09/25 Page 3 of 4
`
`
`
`
`
`
`
`4. Depositions. All depositions (including any expert depositions, see item 3 above) must be
`completed by ____________________. Unless counsel agree otherwise or the Court so orders,
`depositions shall not commence until all parties have completed the initial disclosures required by
`Fed. R. Civ. P. 26(a)(1) or until four weeks from the date of this Order, whichever is earlier.
`Depositions shall proceed concurrently, with no party having priority, and no deposition shall extend
`beyond one business day without prior leave of the Court.
`5. Requests to Admit. Requests to Admit, if any, must be served by ____________________
`[insert date that is no later than 30 days prior to date of close of discovery as set forth in item 6
`below].
`6. All discovery is to be completed by ____________________. Interim deadlines for items 1–5
`above may be extended by the parties on consent without application to the Court, provided the
`parties are certain they can still meet the discovery completion date set forth in this paragraph. The
`discovery completion date may be adjourned only upon a showing to the Court of extraordinary
`circumstances, and may not be extended on consent.
`E. Post-discovery summary judgment motions in the form prescribed by the Court’s Individual Rules of
`Practice may be brought on without further consultation with the Court provided that a Notice of any such
`motion, in the form specified in the Court’s Individual Rules of Practice, is filed no later than one week
`following the close-of-discovery date (item D-6 above) and provided that the moving papers are served by
`____________________, answering papers by ____________________, and reply papers by
`____________________ [the last of these days being no later than six weeks following the close of
`discovery]. Each party must file its respective papers with the Clerk of the Court on the same date that such
`papers are served. Additionally, on the same date that any papers are served and filed, counsel filing and
`serving the papers must arrange to deliver courtesy non-electronic hard copies to the Courthouse for delivery
`to Chambers.
`F. A final pre-trial conference, as well as oral argument on any post-discovery summary judgment
`motions, shall be held on ____________________ [date to be inserted by the Court], at which time the
`Court shall set a firm trial date. The timing and other requirements for the Joint Pretrial Order and/or other
`pre-trial submissions shall be governed by the Court’s Individual Rules of Practice.
`G. All motions and applications shall be governed by Judge Rakoff’s Individual Rules of Practice.
`Counsel shall promptly familiarize themselves with all of the Court’s Individual Rules, as well as with the
`Local Rules for the United States District Court for the Southern District of New York.
`SO ORDERED.
`_____________________________
`JED S. RAKOFF
`U.S.D.J.
`DATED: New York, New York
`___________________________.
`October 31, 2025
`September 24, 2025
`October 31, 2025
`November 5, 2025
`November 19, 2025
`November 26, 2025
`December 5, 2025
`Case 1:25-cv-03484-JSR Document 13 Filed 05/09/25 Page 4 of 4
`
`
`
`
`
`
`
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - x
`Gray
`Plaintiff(s),
`-v-
`Paramount
`Defendant(s).
`- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - x
`CIVIL CASE MANAGEMENT PLAN
`(JUDGE RAKOFF)
`25cv3484 (JSR)
`This Court requires that this case shall be ready for trial on
`10/9/2025.
`After consultation with counsel for the parties, the following Case Management Plan is adopted.
`This plan is also a scheduling order pursuant to Rules 16 and 26(f) of the Federal Rules of Civil Procedure.
`A. The case (is) (is not) to be tried to a jury. [Circle as appropriate]
`B. Joinder of additional parties must be accomplished by ____________________.
`C. Amended pleadings may be filed without leave of Court until ____________________.
`D. Discovery (in addition to the disclosures required by Fed. R. Civ. P. 26(a)):
`1. Documents. First request for production of documents, if any, must be served by
`____________________. Further document requests may be served as required, but no document
`request may be served later than 30 days prior to the date of the close of discovery as set forth in item
`6 below.
`2. Interrogatories. Interrogatories pursuant to Rule 33.3(a) of the Local Civil Rules of the Southern
`District of New York must be served by ____________________. No other interrogatories are
`permitted except upon prior express permission of Judge Rakoff. No Rule 33.3(a) interrogatories
`need be served with respect to disclosures automatically required by Fed. R. Civ. P. 26(a).
`3. Experts. Every party-proponent of a claim (including any counterclaim, cross-claim, or third-
`party claim) that intends to offer expert testimony in respect of such claim must make the disclosures
`required by Fed. R. Civ. P. 26(a)(2) by ____________________. Every party-opponent of such
`claim that intends to offer expert testimony in opposition to such claim must make the disclosures
`required by Fed. R. Civ. P. 26(a)(2) by ____________________. No expert testimony (whether
`designated as “rebuttal” or otherwise) will be permitted by other experts or beyond the scope of the
`opinions covered by the aforesaid disclosures except upon prior express permission of the Court,
`application for which must be made no later than 10 days after the date specified in the immediately
`preceding sentence. All experts may be deposed, but such depositions must occur within the time
`limit for all depositions set forth below.
`
`May 30, 2025
`May 30, 2025
`May 23, 2025
`May 23, 2025
`June 6, 2025
`July 3, 2025
`Liability Phase
`Case 1:25-cv-03484-JSR Document 13 Filed 05/09/25 Page 1 of 4
`
`
`
`
`
`
`
`4. Depositions. All depositions (including any expert depositions, see item 3 above) must be
`completed by ____________________. Unless counsel agree otherwise or the Court so orders,
`depositions shall not commence until all parties have completed the initial disclosures required by
`Fed. R. Civ. P. 26(a)(1) or until four weeks from the date of this Order, whichever is earlier.
`Depositions shall proceed concurrently, with no party having priority, and no deposition shall extend
`beyond one business day without prior leave of the Court.
`5. Requests to Admit. Requests to Admit, if any, must be served by ____________________
`[insert date that is no later than 30 days prior to date of close of discovery as set forth in item 6
`below].
`6. All discovery is to be completed by ____________________. Interim deadlines for items 1–5
`above may be extended by the parties on consent without application to the Court, provided the
`parties are certain they can still meet the discovery completion date set forth in this paragraph. The
`discovery completion date may be adjourned only upon a showing to the Court of extraordinary
`circumstances, and may not be extended on consent.
`E. Post-discovery summary judgment motions in the form prescribed by the Court’s Individual Rules of
`Practice may be brought on without further consultation with the Court provided that a Notice of any such
`motion, in the form specified in the Court’s Individual Rules of Practice, is filed no later than one week
`following the close-of-discovery date (item D-6 above) and provided that the moving papers are served by
`____________________, answering papers by ____________________, and reply papers by
`____________________ [the last of these days being no later than six weeks following the close of
`discovery]. Each party must file its respective papers with the Clerk of the Court on the same date that such
`papers are served. Additionally, on the same date that any papers are served and filed, counsel filing and
`serving the papers must arrange to deliver courtesy non-electronic hard copies to the Courthouse for delivery
`to Chambers.
`F. A final pre-trial conference, as well as oral argument on any post-discovery summary judgment
`motions, shall be held on ____________________ [date to be inserted by the Court], at which time the
`Court shall set a firm trial date. The timing and other requirements for the Joint Pretrial Order and/or other
`pre-trial submissions shall be governed by the Court’s Individual Rules of Practice.
`G. All motions and applications shall be governed by Judge Rakoff’s Individual Rules of Practice.
`Counsel shall promptly familiarize themselves with all of the Court’s Individual Rules, as well as with the
`Local Rules for the United States District Court for the Southern District of New York.
`SO ORDERED.
`_____________________________
`JED S. RAKOFF
`U.S.D.J.
`DATED: New York, New York
`___________________________.
`June 20, 2025
`July 25, 2025
`July 25, 2025
`August 1, 2025
`August 15, 2025
`August 22, 2025
`August 29, 2025
`Case 1:25-cv-03484-JSR Document 13 Filed 05/09/25 Page 2 of 4
`
`
`
`
`
`
`
`Revised Form D—For cases assigned to Judge Rakoff Effective September 10, 2010
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - x
`Gray
`Plaintiff(s),
`-v-
`Paramount
`Defendant(s).
`- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - x
`CIVIL CASE MANAGEMENT PLAN
`(JUDGE RAKOFF)
`25cv3484 (JSR)
`This Court requires that this case shall be ready for trial on
`10/9/2025.
`After consultation with counsel for the parties, the following Case Management Plan is adopted.
`This plan is also a scheduling order pursuant to Rules 16 and 26(f) of the Federal Rules of Civil Procedure.
`A. The case (is) (is not) to be tried to a jury. [Circle as appropriate]
`B. Joinder of additional parties must be accomplished by ____________________.
`C. Amended pleadings may be filed without leave of Court until ____________________.
`D. Discovery (in addition to the disclosures required by Fed. R. Civ. P. 26(a)):
`1. Documents. First request for production of documents, if any, must be served by
`____________________. Further document requests may be served as required, but no document
`request may be served later than 30 days prior to the date of the close of discovery as set forth in item
`6 below.
`2. Interrogatories. Interrogatories pursuant to Rule 33.3(a) of the Local Civil Rules of the Southern
`District of New York must be served by ____________________. No other interrogatories are
`permitted except upon prior express permission of Judge Rakoff. No Rule 33.3(a) interrogatories
`need be served with respect to disclosures automatically required by Fed. R. Civ. P. 26(a).
`3. Experts. Every party-proponent of a claim (including any counterclaim, cross-claim, or third-
`party claim) that intends to offer expert testimony in respect of such claim must make the disclosures
`required by Fed. R. Civ. P. 26(a)(2) by ____________________. Every party-opponent of such
`claim that intends to offer expert testimony in opposition to such claim must make the disclosures
`required by Fed. R. Civ. P. 26(a)(2) by ____________________. No expert testimony (whether
`designated as “rebuttal” or otherwise) will be permitted by other experts or beyond the scope of the
`opinions covered by the aforesaid disclosures except upon prior express permission of the Court,
`application for which must be made no later than 10 days after the date specified in the immediately
`preceding sentence. All experts may be deposed, but such depositions must occur within the time
`limit for all depositions set forth below.
`
`May 30, 2025
`May 30, 2025
`September 24, 2025
`September 24, 2025
`October 3, 2025
`October 20, 2025
`Damages Phase
`Case 1:25-cv-03484-JSR Document 13 Filed 05/09/25 Page 3 of 4
`
`
`
`
`
`
`
`4. Depositions. All depositions (including any expert depositions, see item 3 above) must be
`completed by ____________________. Unless counsel agree otherwise or the Court so orders,
`depositions shall not commence until all parties have completed the initial disclosures required by
`Fed. R. Civ. P. 26(a)(1) or until four weeks from the date of this Order, whichever is earlier.
`Depositions shall proceed concurrently, with no party having priority, and no deposition shall extend
`beyond one business day without prior leave of the Court.
`5. Requests to Admit. Requests to Admit, if any, must be served by ____________________
`[insert date that is no later than 30 days prior to date of close of discovery as set forth in item 6
`below].
`6. All discovery is to be completed by ____________________. Interim deadlines for items 1–5
`above may be extended by the parties on consent without application to the Court, provided the
`parties are certain they can still meet the discovery completion date set forth in this paragraph. The
`discovery completion date may be adjourned only upon a showing to the Court of extraordinary
`circumstances, and may not be extended on consent.
`E. Post-discovery summary judgment motions in the form prescribed by the Court’s Individual Rules of
`Practice may be brought on without further consultation with the Court provided that a Notice of any such
`motion, in the form specified in the Court’s Individual Rules of Practice, is filed no later than one week
`following the close-of-discovery date (item D-6 above) and provided that the moving papers are served by
`____________________, answering papers by ____________________, and reply papers by
`____________________ [the last of these days being no later than six weeks following the close of
`discovery]. Each party must file its respective papers with the Clerk of the Court on the same date that such
`papers are served. Additionally, on the same date that any papers are served and filed, counsel filing and
`serving the papers must arrange to deliver courtesy non-electronic hard copies to the Courthouse for delivery
`to Chambers.
`F. A final pre-trial conference, as well as oral argument on any post-discovery summary judgment
`motions, shall be held on ____________________ [date to be inserted by the Court], at which time the
`Court shall set a firm trial date. The timing and other requirements for the Joint Pretrial Order and/or other
`pre-trial submissions shall be governed by the Court’s Individual Rules of Practice.
`G. All motions and applications shall be governed by Judge Rakoff’s Individual Rules of Practice.
`Counsel shall promptly familiarize themselves with all of the Court’s Individual Rules, as well as with the
`Local Rules for the United States District Court for the Southern District of New York.
`SO ORDERED.
`_____________________________
`JED S. RAKOFF
`U.S.D.J.
`DATED: New York, New York
`___________________________.
`October 31, 2025
`September 24, 2025
`October 31, 2025
`November 5, 2025
`November 19, 2025
`November 26, 2025
`December 5, 2025
`Case 1:25-cv-03484-JSR Document 13 Filed 05/09/25 Page 4 of 4
`
`
`
`
`
`
`
`
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