Further Updated Briefing and Discovery Schedule for Citgo Sale Hearing

Deadline

Deadline for the Special Master to submit his Final Recommendation

July 2

Deadline to serve written discovery on the party (or parties) whose bid is selected as the Final Recommendation

July 7

Opening expert reports due

July 7

Deadline for the filing of any notice of objections to the Special Master’s Final Recommendation. The notice must state with particularity the bases for each objection known at that time. Parties may only seek discovery that is reasonably related to the issues raised in the initial notices of objections that are filed on July 7.

July 7

Deadline for any Competing Objector to disclose its own bid materials (such materials to be commensurate with those disclosed by the Special Master of the recommended bid)

July 9

Deadline to serve written discovery on a Competing Objector

July 11

Deadline to serve responses and objections for discovery requests served after the Final Recommendation

July 15

Deadline to meet and confer regarding the scope of discovery to be produced in response to discovery requests served after submission of the Final Recommendation

July 16

Deadline to complete document productions in response to discovery requests served before the submission of the Final Recommendation and substantially complete document productions in response to discovery requests served after the submission of the Final Recommendation