Proposed Case Management Plan And Report Of Rule 26(f) Meeting (Judge Parker) | Pdf Fpdf Doc Docx | New York

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Proposed Case Management Plan And Report Of Rule 26(f) Meeting (Judge Parker) | Pdf Fpdf Doc Docx | New York

Last updated: 3/9/2021

Proposed Case Management Plan And Report Of Rule 26(f) Meeting (Judge Parker)

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Last Updated: March 16, 2017 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK -------------------------------------------------------------X : : : : : : : : : : : : : X CIVIL ACTION NO.: Plaintiff, against Defendant. -------------------------------------------------------------- REPORT OF RULE 26(f) MEETING AND PROPOSED CASE MANAGEMENT PLAN In accordance with Federal Rule of Civil Procedure 26(f), counsel for the parties spoke on _______________ and exchanged communications thereafter, and submit the following report of their meeting for the court's consideration: 1. Summary of Claims, Defenses, and Relevant Issues Plaintiff: Defendant: 2. Basis of Subject Matter Jurisdiction: ___________________________________ American LegalNet, Inc. www.FormsWorkFlow.com Last Updated: March 16, 2017 3. Subjects on Which Discovery May Be Needed Plaintiff: Defendant: 4. Informal Disclosures The information required by Rule 26(a)(1) of the Federal Rules of Civil Procedure was disclosed by Plaintiff(s) on ____________. In addition, on _______________, Plaintiff(s) produced/will produce an initial set of relevant documents identified in its Initial Disclosures and will continue to supplement its production. The information required by Rule 26(a)(1) of the Federal Rules of Civil Procedure was disclosed by Defendant(s) on ____________. In addition, on _____________, Defendant(s) produced/will produce an initial set of relevant documents identified in its Initial Disclosures and will continue to supplement its production. 5. Formal Discovery The parties jointly propose to the Court the following discovery plan: a. b. All fact discovery must be completed by ____________. The parties are to conduct discovery in accordance with the Federal Rules of Civil Procedure and the Local Rules of the Southern District of New York. The following interim deadlines may be extended by the parties on consent without application to the Court, American LegalNet, Inc. www.FormsWorkFlow.com Last Updated: March 16, 2017 provided that the parties meet the deadline for completing fact discovery set forth in 3(a) above. i. Depositions: Depositions shall be completed by ______ and limited to no more than _____ depositions per party. Absent an agreement between the parties or an order from the Court, non-party depositions shall follow initial party depositions. Interrogatories: Initial sets of interrogatories shall be served on or before ___________. All subsequent interrogatories must be served no later than 30 days prior to the discovery deadline. Requests for Admission: Requests for admission must be served on or before ______________. Requests for Production: Initial requests for production were/will be exchanged on __________ and responses shall be due on _______________. All subsequent requests for production must be served no later than 30 days prior to the discovery deadline. Supplementation: Supplementations under Rule 26(e) must be made within a reasonable period of time after discovery of such information. ii. iii. iv. v. 6. Anticipated Discovery Disputes Are there any anticipated discovery disputes? Does either party seek limitations on discovery? Describe. 7. Amendments to Pleadings a. b. Are there any amendments to pleadings anticipated?________________ Last date to amend the Complaint: ______________________________ American LegalNet, Inc. www.FormsWorkFlow.com Last Updated: March 16, 2017 8. Expert Witness Disclosures At this time, the parties do/do not (circle one) anticipate utilizing experts. Expert discovery shall be completed by ___________________________________________________. 9. Electronic Discovery and Preservation of Documents and Information a. b. Have the parties discussed electronic discovery? ___________________ Is there an electronic discovery protocol in place? If not, when the parties except to have one in place? _______________________________________________ c. Are there issues the parties would like to address concerning preservation of evidence and/or electronic discovery at the Initial Case Management Conference? 10. Anticipated Motions 11. Early Settlement or Resolution The parties have/have not (circle one) discussed the possibility of settlement. The parties request a settlement conference by no later than ___________________. The following information is needed before settlement can be discussed: 12. Trial a. The parties anticipate that this case will be ready for trial by __________. American LegalNet, Inc. www.FormsWorkFlow.com Last Updated: March 16, 2017 b. c. Judge at this time. d. 13. The parties anticipate that the trial of this case will require _______ days. The parties do/do not (circle one) consent to a trial before a Magistrate The parties request a jury/bench (circle one) trial. Other Matters Respectfully submitted this _____ day of _________. ATTORNEYS FOR PLAINTIFF(S): ______________________ ATTORNEYS FOR DEFENDANT(S): __________________________ American LegalNet, Inc. www.FormsWorkFlow.com

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