`Chambers
`Robert Abrams Building for Law and Justice
`P.O. Box 7344, Capitol Station
`Albany, New York 12224
`(518) 242-3710
`fax (518) 242-3711
`
`State of New York
`Supreme Court: County of Schoharie DISCOVERY STIPULATION
`
` &
`
`Title: Federal National Mortgage Association fka Fannie Mae v.
`Dufek, Jr., et al.
`
`Index No: 2022-3
`
` ORDER
`
`It is hereby STIPULATED AND ORDERED that discovery shall proceed as follows:
`
`1) All paper discovery, including the exchange of bill of particulars, authorizations and responses to discovery
` demands shall be completed on or before_________________________.
`
`2) Party depositions shall be held on or before__________________________________.
` Non-party depositions shall be held on or before ______________________________.
`
`3) Independent medical exam(s) are to be held on or before ____________________ and the report is to be
`provided 60 days thereafter.
`
`4) Plaintiff shall file the note of issue on or before __________________________________.
`
`5) Expert disclosure shall be in compliance with the Expert Disclosure rule for the Third Judicial District.
`
`6) Counsel shall serve dispositive motions within 60 days of the filing of the note of issue (see CPLR 3212).
` Such motions shall neither be returnable on nor adjourned to a date that is less than 60 days before trial.
`
`7) A compliance conference is scheduled for _____________________________.
`
`8) A conference is required prior to submission of any discovery motion(s).
`
`9) Further directive(s) _________________________________________________________________
`
`___________________________________________________________________________________.
`No scheduled deadline may be extended without the Court’s prior approval, which approval must be reduced to
`writing. The parties may not, without such approval, stipulate to any extensions of the dates set forth herein.
`
`________________________________________ _________________________________
`(Plaintiff Counsel - sign and print name)
` (Defendant Counsel - sign and print name)
`
`Dated: _______________________________
`
`
`
`____________________________
` James H. Ferreira, A.J.S.C.
`
`
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