Contract analysis

Section 1: Document discovery 1.1 Initial Document Production. Each party shall serve its initial production of documents responsive to all outstanding document requests no later than January 15, 2025. As of the date of this Order, Plaintiff/Counterclaim Defendant Belmont Ridge Bank NA has received eighty-seven (87) document requests from Defendants/Counterclaim Plaintiffs, served in connection with Defendants' First

Section 2: Interrogatories 2.1 Responses to Outstanding Interrogatories. Plaintiff/Counterclaim Defendant Belmont Ridge Bank NA shall serve its responses and objections to Defendants/Counterclaim Plaintiffs' First Set of Interrogatories, consisting of fourteen (14) interrogatories (including subparts), no later than January 15, 2025. The First Set of Interrogatories was served on Plaintiff/Counterclaim Defendant on o

Section 3: Confidentiality / Protective Order The parties shall submit a stipulated confidentiality and protective order to the Court for so-ordering no later than December 20, 2024. The proposed protective order shall govern the treatment of confidential business information, proprietary financial records, internal bank documents (including but not limited to credit memoranda, risk assessments, internal audit report

Section 4: Fact Depositions 4.1 Deposition Schedule. The parties have conferred and agreed to the following deposition schedule for fact witnesses, subject to the availability of each deponent. In the event a deponent is unavailable on the scheduled date, the parties shall meet and confer to select a mutually agreeable alternative date that does not materially disrupt the overall discovery schedule or the sequence of

Section 5: Expert discovery 5.1 Expert Disclosures. Each party shall serve its initial expert disclosures, including expert reports prepared pursuant to CPLR 3101(d)(1)(i), no later than May 15, 2025. Initial expert disclosures shall include the subject matter on which each expert is expected to testify, the substance of the facts and opinions to which the expert is expected to testify, a summary of the grounds for e

Section 6: Motions 6.1 Dispositive Motions. Any motions for summary judgment or partial summary judgment pursuant to CPLR 3212 shall be filed no later than September 15, 2025. All motions for summary judgment shall be made returnable in accordance with the Court's Individual Rules and shall comply with the requirements of 22 NYCRR § 202.70(g), Rule 19-a (Statement of Material Facts). Opposition papers shall be filed

Section 7: Settlement / Alternative Dispute Resolution The Court encourages the parties to engage in meaningful settlement discussions or alternative dispute resolution at an appropriate time in this litigation. The Commercial Division offers a mediation program, and the parties are advised that mediation can be a valuable tool for resolving complex commercial disputes efficiently and cost-effectively, particularly i

Section 8: Compliance Conferences A compliance conference shall be held on March 21, 2025, at a time to be scheduled by the Court, to address the status of document discovery, any outstanding privilege disputes, the progress of depositions, and any other issues that have arisen during the course of fact discovery. The parties shall be prepared to advise the Court of the status of all outstanding discovery and to iden

Section 9: Modifications This schedule may be modified only by written stipulation of the parties approved by the Court, or by Order of the Court upon a showing of good cause. The parties are reminded that the Commercial Division's commitment to the efficient resolution of complex commercial disputes requires adherence to established discovery schedules, and that requests for extensions will not be granted routinely.

Section 10: Reservation of Rights Nothing in this Order shall be construed to limit any party's right to seek appropriate relief from the Court at any time during the pendency of this action, including but not limited to motions to compel disclosure or discovery, motions for protective orders, motions for sanctions for discovery abuses, motions in limine, or any other relief to which a party may be entitled under the