Certification And Report Of Frcp 26f Conference And Disctovery Plan (Page 2 of 3) in pdf

Certification And Report Of Frcp 26f Conference And Disctovery Plan Page 2

Discovery Plan. The parties jointly propose to the court the following discovery

plan: [Use separate paragraphs or subparagraphs as necessary if parties disagree.]

a) All discovery shall be commenced in time to be completed by

__________________________(date).

[if needed] Discovery on

__________________________________________

____________________________________________________________

(identify any issues requiring early discovery) will be completed by

______________________ (date).

Discovery Limits:

Maximum of _____ (ordinarily 20) interrogatories by each party to any

other party .

Maximum of _____ (ordinarily 20) requests for admission by each party

to any other party.

Maximum of _____ depositions by plaintiff(s) and ______ by defendant(s)

(ordinarily 6 each) [or ____ by each plaintiff and _____ by each

defendant].

Reports from retained experts under Rule 26(a)(2) will be due:

-from plaintiff(s) by _______________________(date)

-from defendant(s) by _______________________(date)

Supplementations under Rule 26(e) due _______________ (list time(s) or

interval(s))

Other Items. [Attach separate paragraphs as necessary if parties disagree.]

The parties [ ] request

[ ] do not request

a conference with the court

before entry of the scheduling order.

All potentially dispositive motions should be filed by ______________

(date, ordinarily one month after the close of discovery)

Settlement:

[ ] is likely

[ ] is unlikely

[ ] cannot be evaluated prior to ____________________(date)

[ ] may be enhanced by use of the following ADR procedure:

[ ] Mediated Settlement Conference

[ ] binding arbitration

[ ] judicial settlement conference

[ ] other _____________________

Certification And Report Of Frcp 26f Conference And Disctovery Plan Page 2