Extract to table

Phase 1 discovery shall be completed by the close of the conditional certification briefing period, i

Merits discovery Commencement: Phase 2 merits discovery shall commence upon the later of: (a) the Court's ruling on the Motion for Conditional Certification and expiration of the opt-in period (if conditional certification is granted), or (b) the date of the Court's order denying conditional certification (in which case merits discovery shall commence immediately and proceed as to the Named Plaintiff's individual claims)

Merits discovery Cutoff: All merits discovery, including all fact depositions, written discovery (interrogatories, requests for production of documents, and requests for admission), and expert discovery, shall be completed no later than March 15, 2026

Word, Excel, and PDF) shall be produced in native format with associated metadata

Email communications shall be produced in a format that preserves metadata, including date, time, sender, recipient, and subject line fields

Interrogatory Limit: Each side shall be limited to twenty-five (25) interrogatories, including all discrete subparts, consistent with Federal Rule of Civil Procedure 33(a)(1)