The End-of-Fact-Discovery Status Hearing is a substantive hearing. The parties should be prepared to report to the Court: (1) whether expert discovery is necessary; (2) whether dispositive motions will be filed; and (3) when they will be available to try the case.

The expert discovery discussion will not be perfunctory. The Court will ask questions that the parties should be ready to answer regarding the issues any experts will testify to, what qualifies them as experts to opine on such issues, and specifically, whether the expert's opinion is essential to the Court's summary judgment review or whether the opinion goes solely to damages. The Court will also inquire as to the amount of time the parties will need to file their expert reports and take their depositions.

As a general matter, the Court does not stay or extend discovery so parties may engage in settlement negotiations. The two tracks are parallel and the Court expects the parties to simultaneously litigate and negotiate.