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Rule 26(F) Report And Proposed Scheduling Order (Non-Patent Cases) - United States District Court Page 3

(i) The identity of any expert who may testify at trial regarding issues on which

the party has the burden of persuasion must be disclosed on or before

____________.

(ii) The initial expert written report completed in accordance with Fed. R. Civ.

P. 26(a)(2)(B) must be served on or before ____________.

(B) Rebuttal experts.

(i) The identity of any experts who may testify in rebuttal to any initial expert

must be disclosed on or before __________.

(ii) Any rebuttal expert’s written report completed in accordance with Fed. R.

Civ. P. 26(a)(2)(B) must be served on or before __________.

(3) All expert discovery must be completed by _____________.

(e) Other Discovery Issues.

(1) Protective Order. The parties have discussed whether they believe that a

protective order is necessary to govern discovery and jointly submit a [proposed

protective order/report identifying areas of disagreement].

(The parties are encouraged, though not required, to use Form 6 as a template

for a proposed protective order.)

(2) Discovery of Electronically Stored Information. The parties have discussed

disclosure, discovery, and preservation of electronically stored information,

including the form in which it should be produced. The parties have reached the

following agreements and identified the following issues:

(3) Claims of Privilege or Protection. The parties have discussed issues regarding

the protection of information by a privilege or the work-product doctrine, as

required by Fed. R. Civ. P. 26(f)(3)(D), including whether the parties agree to a

procedure to assert these claims after production or have any other agreements

under Fed. R. Evidence 502. The parties request the Court to include the

following agreement in the scheduling order:

(4) The parties:

agree that a party should be required to request an informal conference with

the Court before filing a discovery motion;

agree that a party should not be required to request an informal conference

with the Court before filing a discovery motion; or

Rule 26(F) Report And Proposed Scheduling Order (Non-Patent Cases) - United States District Court Page 3