Report Of Parties Planning Meeting Page 2
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4USDC/ATTY-003 | LR 16.1 (Rev. 2/07) Report of Parties Planning Meeting
4.
Discovery Plan. The parties jointly propose to the court the following discovery plan:
[Use separate paragraphs or subparagraphs as necessary if parties disagree.]
Discovery will be needed on the following subjects:
Disclosure of electronically stored information should be handled as follows:
The parties have agreed to an order regarding claims of privilege or of protection as trial-
preparation material asserted after production, as follows:
Select:
This action
suitable for designation as a complex case requiring special case
management procedures and additional pretrial conferences. If the parties and attorneys believe that
the case is complex, the basis for that belief is:
The last date to serve discovery requests is ____________________. The last date on which
to take a discovery deposition is 45 days after the last date to serve discovery requests. The last date
on which to take a discovery deposition is known as the “discovery completion date.” [Discovery
on ____________________to be completed by ____________________.]
Select:
The parties
adopt the discovery limits set forth in the Federal Rules of Civil
Procedure. If the parties and attorneys believe that more discovery is needed, the basis for that
belief is:
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