UNITED STATES DISTRICT COURT USDC SDNY SOUTHERN DISTRICT OF NEW YORK DOCUMENT === ------ == 2-2 = === === === === === === -----------X ELECTRONICALLY FILED PARADIGM CLINICAL RESEARCH CENTERS, INC. DOC #: and PARADIGM CLINICAL RESEARCH CENTERS, LLC, ]] DATE FILED: 12/8/2023

Plaintiff, 23-CV-6875 (JPC) (KHP) -against- INITIAL CASE MANAGEMENT CONFERENCE ORDER PARADIGM HEALTH, INC., Defendant. +--+ ----X KATHARINE H. PARKER, United States Magistrate Judge: On December 7, 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 March 25, 2024 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 January 24, 2025. The deadline to complete all discovery is May 30, 2025. 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 Update. The parties shall submit a joint letter to the Court by January 29, 2024 to provide an update on the progress of discovery, and any anticipated discovery disputes. Consent. The parties are reminded that they have the option to consent to conduct all proceedings, including a trial, before the undersigned pursuant to

(c). If all parties consent, they shall complete and file the Consent form available on the Court’s website

at https://www.nysd.uscourts.gov/forms/consent-proceed-us-magistrate-judge. This Order is not meant to interfere in any way with the parties’ absolute right to have dispositive motions and/or a trial before a United States District Judge, but is merely an attempt at preserving scarce judicial resources and reminding the parties of their option pursuant to

(c). SO ORDERED.

2 DATED: New York, New York December 8, 2023 Kel hau H (2 aks KATHARINE H. PARKER United States Magistrate Judge