United States District Court, S.D. Georgia, Savannah Division
UNITED STATES OF AMERICA ex rel. JOLIE JOHNSON et al., Relators,
BETHANY HOSPICE AND PALLIATIVE CARE OF COASTAL GEORGIA, LLC. et al., Defendants.
Bothwell Law Group James L. Roberts, IV Georgia Bar No.
069920 Counsel for Relators Jolie Johnson and The Estate of
L. Roberts, IV Georgia Bar No. 608580 Counsel for Defendants
JOINT LIMITED SCHEDULING AND DISCOVERY ORDER
Jolie Johnson and the Estate of Debbie Helmly and Defendant
Bethany Hospice and Palliative Care of Coastal Georgia, LLC
hereby submit this Proposed Joint Limited Scheduling and
Discovery Order pursuant to this Court's Order dated May
2, 2019. The parties, through respective counsel, met and
conferred on May 8, 2019 and agreed as follows:
Proposed Discovery Schedule and Cut-Off
Parties hereby propose the following discovery schedule
regarding Relators retaliation claim:
Responses to Relator Johnson's First Request for
Production of Documents to Defendant Bethany Hospice and
Palliative Care of Coastal Georgia, LLC (f/k/a Bethany
Hospice of Coastal Georgia, LLC) will be due June 3, 2019.
New discovery related to the retaliation claims may be served
on or after June 3, 2019.
Fact discovery cut-off date is December 15, 2019.
Expert discovery period to begin on December 18, 2019.
Deadline to disclose affirmative experts and exchange expert
reports is December 18, 2019.
Deadline to depose affirmative experts is January 31, 2020.
Deadline to disclose rebuttal experts is February 27, 2020.
Expert discovery period to end on March 31, 2020, by which
date rebuttal expert ...