STIPULATION AND[ PROPOSED] ORDER REGARDING PLAINTIFF'S PREVIOUSLY SERVED WRITTEN DISCOVERY

EDMUND F. BRENNAN, Magistrate Judge.

This Stipulation is entered into by and between Plaintiff Jamisi Jermaine Calloway, Defendant M. Veal, and Defendant Alicia Terry, administrator of the Estate of deceased Defendant Raymond Andreasen, MD1.

WHEREAS on September 13, 2011, Plaintiff Jamisi Jermaine Calloway served on Defendants Veal and Andreasen Requests for Admission, Requests for Production, and Interrogatories in the above-captioned matter (the "written discovery requests");

WHEREAS Defendants Veal and Andreasen objected to Plaintiff Calloway's written discovery requests on October 13, 2011 on the basis of, inter alia, their inability to decipher the particular defendant to which certain requests were directed and the type of discovery sought by certain requests; and

WHEREAS on July 30, 2014 the Court ordered Defendants to respond to Plaintiff Calloway's written discovery requests;

It is hereby STIPULATED and AGREED that:

1. Plaintiff Calloway shall be permitted to revise the written discovery requests served on September 13, 2011, to clarify the information requested and the party to whom the requests are directed;

2. Requests previously implicating Defendant Andreasen shall be redirected, as applicable, to Defendant Veal or Defendant Terry, administrator of the Estate of deceased Defendant Raymond Andreasen, MD;

3. The revised written discovery requests shall supersede the written discovery requests served on September 13, 2011 and, as such, (a) Defendants need only respond to the revised written discovery requests; and (b) the written discovery requests served on September 13, 2011 shall not be counted against any quantitative or other applicable limit on Plaintiff Calloway's written discovery;

4. Such revised written discovery requests shall be served on the Defendants no later than August 22, 2014;

5. Within 30 days of service of the revised written discovery requests, Defendants shall respond to the revised written discovery requests;

6. Any motion to compel with regard to Defendants' responses to the revised written discovery requests shall be filed within 30 days of the service of those responses;

7. Revision of the written discovery requests shall in no way operate as an admission that the written discovery requests Plaintiff Calloway served on September 13, 2011 were in any way deficient or improper; and

8. Revision of the written discovery requests shall in no way operate as a waiver of Plaintiff Calloway's right or ability to seek additional discovery pursuant to the Court's July 30, 2014 Order.

IT IS SO ORDERED.