AMENDED COMPLAINT

Unless otherwise ordered by the Court, the party filing an amended complaint must file and serve: (a) a clean copy of the amended complaint; and (b) a copy of the amended complaint in which stricken material has been lined through or enclosed in brackets and new material has been underlined or set forth in bold face type. Ver. 25.01 (December 1, 2025) 57 RULE 7016-1 PRETRIAL PROCEDURES (a) General. The Court may, in any adversary proceeding, direct the attorney for a party or a party not represented by an attorney to appear before it for a preliminary scheduling or pretrial conference pursuant to Federal Bankruptcy Rule 7016.

(b) Pretrial Statement. Where required by Court order, each party must file a pretrial memorandum, with copies sent to all other attorneys of record or parties not represented by an attorney. Each party must state the following in its pretrial memorandum: (1) a brief statement of facts that the party proposes to prove in support of a claim or defense, together with a statement of legal theories and citations of authorities; (2) any required pleading amendments; (3) any pleaded, but abandoned, issue; (4) stipulations of fact; (5) the details of the damage claimed or any other relief sought; (6) a list of the documents and records to be offered in evidence by the party at the trial other than those expected to be used solely for impeachment, identifying which documents the party expects to introduce in evidence by stipulation and/or without the authentication required by the Federal Rules of Evidence; (7) a list of the names and specialties of experts that the party proposes to call as witnesses; and (8) a statement of any matter that must be resolved before trial. (c) Required Pre-Filing of Exhibits.

Unless otherwise ordered by the Court, each party must pre-file all exhibits which that party intends to introduce into evidence during any adversary proceeding, except for exhibits to be offered solely for rebuttal or impeachment. Ver. 25.01 (December 1, 2025) 58 RULE 7026-1 DISCOVERY - GENERAL (a) Discovery Request Limits. A party may not serve on any other party in an adversary proceeding more than thirty (30) interrogatories, thirty (30) requests for production, and thirty (30) requests for admission, including all parts and sub-parts.

(b) Timely Written Discovery Requests Required. All discovery requests must be made at a sufficiently early date to assure that the time for response expires and discovery disputes are resolved before any discovery deadlines set by the Court. The party serving discovery requests must promptly provide the requests in electronic form that may be edited when requested by the opposing party. (c) Discovery to Proceed Despite Existence of Disputes.

Unless otherwise ordered by the Court, a discovery dispute as to one matter does not justify delay in taking or responding to any other discovery. (d) Discovery Stayed Pending Resolution of Federal Bankruptcy Rule 7012(b) Motion. The filing of a motion pursuant to Federal Bankruptcy Rule 7012(b) stays discovery unless discovery relates to matters outside the scope of the motion. (e) Format of Responses.

Responses to discovery must restate each request followed by the response or a brief statement of the grounds for objection. (f) Conference of Attorneys Required. Attorneys must confer in person, telephonically, or by videoconference concerning a discovery dispute and make good faith attempts to resolve their differences. The Court will not resolve a discovery dispute unless the moving party has filed a certificate stating: (1) the date, time, and place of the discovery conference, the names of all persons participating, and any unresolved issues remaining; or Ver.

25.01 (December 1, 2025) 59 (2) the moving party’s attempts to hold such a conference without success. (g) Deposition of an Expert. The party taking the deposition of an expert must pay a reasonable fee for the time spent by the expert in deposition and traveling to and from the deposition. The party designating the expert will pay any fee charged by the expert for time spent in preparing for the deposition.

(h) Production Expenses. A party in interest requesting copies of documents that were produced for inspection must pay the actual, reasonable costs of copying, scanning, and/or delivering the documents. (i) Discovery Guidelines. The Discovery Guidelines adopted by the Court and set forth in Appendix C govern the conduct of discovery.