Attorneys Planning Meeting Report Page 2

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on _______________ ___, 20 ____, at ___ __. m.
e.
The parties _____ have exchanged or _____ will exchange by ___/___/___ the initial
disclosures required by Rule 26(a)(1).
f.
Pursuant to Fed. R. Civ. P. 5(b)(2)(D), the parties agree to receive all items required to
be served under Fed.R.Civ.P. 5(a) by either (i) notice of electronic filing, or (ii) e-mail
transmission. Such electronic service will constitute service and notice of entry as
required by those rules. Any right to service by USPS mail is waived.
DISCOVERY PLAN: The parties jointly propose to the court the following discovery plan:
2.
Use separate paragraphs or subparagraphs as necessary if the parties disagree.
a.
Discovery is necessary on the following subjects: Briefly describe the subject areas in
which discovery will be needed.
b.
Discovery Phases.
Specify whether discovery will (i) be conducted in phases, or (ii) be limited to or
focused upon particular issues. If (ii), specify those issues and whether discovery will
be accelerated with regard to any of them and the date(s) on which such early discovery
will be completed.
c.
Designate the discovery methods to be used and the limitations to be imposed.
(1)
For oral exam depositions, (i) specify the maximum number for the plaintiff(s)
and the defendant(s), and (ii) indicate the maximum number of hours unless
extended by agreement of the parties.
Oral Exam Depositions
Plaintiff(s)
Defendant(s)
Maximum no. hrs. per deposition
(2)
For interrogatories, requests for admissions, and requests for production of
documents, specify the maximum number that will be served on any party by
any other party.
Interrogatories
Admissions
Requests for production of documents

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