MEMORANDUM AND PRE-HEARING SCHEDULING ORDER

CATHERINE D. PERRY, District Judge.

IT IS HEREBY ORDERED that this matter is set for a preliminary injunction hearing on Thursday, October 6, 2016 at 9:00 a.m. in Courtroom 14-South.

IT IS FURTHER ORDERED that plaintiff's Motion for Expedited Discovery [16] is granted only to the extent set out below, and the following schedule shall apply to the preliminary injunction hearing and will be modified only upon a showing of exceptional circumstances:

1. Defendant shall answer or otherwise respond to plaintiff's Complaint and Request for Injunctive Relief no later than August 22, 2016.

2. The parties shall complete fact discovery for purposes of the preliminary injunction hearing no later than September 28, 2016.

(a) All responses to written discovery shall be made within fifteen (15) calendar days from email receipt of discovery requests.

(b) The parties shall give five (5) days' advance notice of depositions and shall cooperate in the scheduling of depositions.

3. Each party shall disclose its expert witnesses no later than August 31, 2016, with such disclosure to include the general subject matter of the experts' testimony. Expert reports shall be provided no later than September 15, 2016, and expert depositions shall be completed no later than September 28, 2016.

4. Any motion for protective order governing the disclosure of discovery material shall be filed no later than 4:30 p.m. on August 15, 2016. With any motion, the parties shall submit a proposed stipulated Protective Order for Court approval and shall email a word processing version of the proposed order to my Judicial Assistant at brian_crow@moed.uscourts.gov.

IT IS FURTHER ORDERED that the Court will hold a telephone status conference with counsel on September 6, 2016 at 4:00 p.m. Plaintiff's counsel shall place the call and have all participants on the line before connecting my chambers at 314-244-7520.

IT IS FURTHER ORDERED that no later than 5:00 p.m. on September 29, 2016, the parties shall file the following:

1. Witneses: A list of all proposed witnesses, identifying those witnesses expected to be called to testify at the hearing.

2. Exhibits: A list of all exhibits to be offered into evidence at the hearing (plaintiff to use Arabic numerals and defendant to use letters, e.g., Pltf-1, Deft-A) and provide copies of all exhibits to opposing counsel.

3. Proposed Findings and Conclusions: Proposed findings of fact and conclusions of law, citing authorities in support of the proposed legal conclusions.

4. Estimated Length of Hearing: File a JOINT statement setting out the estimated length of the hearing.

5. Bond Proposal: Plaintiff shall submit a bond proposal as required by Federal Rule of Civil Procedure 65(c).

6. Proposed Form of Relief: Plaintiff shall submit a proposed form of preliminary injunction and email a word processing version of this document to my judicial assistant.