USDC SDNY UNITED STATES DISTRICT COURT DOCUMENT SOUTHERN DISTRICT OF NEW YORK ELECTRONICALLY FILED DAVID CLARK COMPANY, INC., DATE FILED: 5/8/2023 Plaintiff, 23-CV-1233 (ALC) (KHP) -against- INITIAL CASE MANAGEMENT ROANWELL LLC, CONFERENCE ORDER Defendant. +--+ ----X KATHARINE H. PARKER, United States Magistrate Judge: On May 8, 2023, the parties appeared for an Initial Case Management Conference. After review of the pleadings and consultation with the parties, the following Scheduling Order is entered pursuant to Rule 16 of the Federal Rules of Civil Procedure: Pleadings, Parties, and Motions. The parties shall have until June 15, 2023 to amend the pleadings and join parties. No further amendments or joinder of parties thereafter absent good cause. Discovery. The deadline to complete fact discovery is February 19, 2024. The deadline to exchange initial disclosures is February 19, 2024. The deadline for expert discovery is May 31, 2024. Discovery Disputes. The parties shall follow the Court’s Individual Procedures with respect to any discovery disputes. See https://nysd.uscourts.gov/hon-katharine-h-parker. Rule 1 and Rule 26(b)(1). Counsel shall comply with Rule 1 and Rule 26(b)(1) in the conduct of discovery. Document Requests. Counsel shall be fully familiar with their obligations under Rules 34 and 26(g) and consider and discuss ways to ensure compliance and minimize disputes

regarding overbreadth and specificity of requests and responses. A failure to comply with this responsibility carries serious consequences. Requests for any and all documents on a broad topic are presumptively improper. Likewise, courts have held that an objection that does not appropriately explain its grounds is forfeited. See, e.g., Wesley Corp. v. Zoom T.V. Prods., LLC, No. 17-100212018,

, at *4 (E.D. Mich. Jan. 11, 2018); Fischer v. Forrest, No. 14 Civ. 01304 (PAE) (AJP),

(S.D.N.Y. Feb. 28, 2017) (“[A]ny discovery response that does not comply with Rule 34’s requirement to state objections with specificity (and to clearly indicate whether responsive material is being withheld on the basis of objection) will be deemed a waiver of all objections (except as to privilege).”). Status Letter. By Wednesday, June 7, 2023, the parties shall file a joint status letter with the Court, including updates on the parties’ progress with discovery. SO ORDERED. DATED: New York, New York May 8, 2023 ket haut H (Z ah KATHARINE H. PARKER United States Magistrate Judge