In The United States District Court For The District Of New Mexico Form (Page 2 of 4) in pdf

In The United States District Court For The District Of New Mexico Form Page 2

STIPULATIONS

The parties hereto stipulate and agree that venue is properly laid in this District; that the

United States District Court for the District of New Mexico has jurisdiction of the parties and the

subject matter.

The parties are willing to further stipulate to the following facts:

The parties further stipulate and agree that the law governing this case is:

PLAINTIFF'S CONTENTIONS:

DEFENDANT'S CONTENTIONS

PROVISIONAL DISCOVERY PLAN

The parties jointly propose to the Court the following discovery plan: (Use separate

paragraphs or subparagraphs as necessary if parties disagree.)

List all witnesses who, at this time, you think will either testify or be deposed, giving their name,

title, address and a brief summary of their testimony. It is insufficient to list witnesses’ addresses,

save for clients, “in care of counsel.”

List all documents which you believe, at this time, will be exhibits at the trial.

List all experts who you believe, at this time, will testify at the trial, giving their name, address,

area of expertise, and a brief summary of the anticipated testimony.

Discovery will be needed on the following subjects: (Brief description of subjects on which

discovery will be needed.)

Maximum of ______ interrogatories by each party to any other party. (Responses due

___________ days after service).

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Version 2: December 2006

In The United States District Court For The District Of New Mexico Form Page 2