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514736/2015
NYSCEF DOC. NO. 116 RECEIVED NYSCEF: 05/17/2017
Defendant.
WHEREAS, under the disclosure deadlines set forth in the Preliminary Conference
Order, dated August 23, 2016 (Dkt. No. 76), Plaintiff A.J. Richard & Son, Inc.'s ("A.J. Richard")
expert disclosures deadline would have been March 15, 2017, Defendant Forest City Ratner
Companies, LLC's ("Forest City") expert disclosure deadline would have been April 15, 2017,
and the end date for all disclosure would have been May 15, 2017;
("Greenland");
WHEREAS, in March 2017, counsel for A.J. Richard and counsel for Forest City
conferred and agreed, in light of ongoing party and third-party discovery, including the
Greenland Subpoena, to extend A.J. Richard's expert disclosure deadline until 30 days after
Greenland's compliance with the Subpoena, to be followed in 30 days by Forest City's expert
disclosure deadline and 30 days thereafter by the end of all disclosure; and
WHEREAS, counsel for Greenland has informed counsel for A.J. Richard that Greenland
expects its production in response to the Subpoena to be complete by the week of May 29, 2017;
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FILED: KINGS COUNTY CLERK 05/17/2017 12:24 PM INDEX NO. 514736/2015
NYSCEF DOC. NO. 116 RECEIVED NYSCEF: 05/17/2017
for A.J. Richard and Forest City, that the remaining disclosure deadlines are modified as follows:
A.J. Richard shall provide expert disclosure by: July 31, 2017;
Forest City shall provide expert disclosure by: August 31, 2017; and
Provided, however, that in the event the Greenland production is not complete by June 30, 2017,
the Parties shall renegotiate these disclosure deadlines as reasonably necessary to provide the
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FILED: KINGS COUNTY CLERK 05/17/2017 12:24 PM INDEX NO. 514736/2015
NYSCEF DOC. NO. 116 RECEIVED NYSCEF: 05/17/2017
signed in counterparts, and facsimile and e-mail signatures will constitute originals for purposes
of this stipulation.
By: By:
Robert H. Baron Harold P. W6injB erger
0,
Rory A. Leraris Susan Jacquemot
Members of the Firm Leah S. Friedman
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