Local Rule 16.2: Preliminary Pretrial Conference

16.2 Preliminary Pretrial Conference

(a) Exempt Cases. Unless the court orders otherwise, this rule does not apply to proceedings described in Fed. R. Civ. P. 26(a)(1)(B).

(b) Filings Before Preliminary Pretrial Conference. Each of the following documents must be filed no later than seven days before the preliminary pretrial conference:

(1) Preliminary Pretrial Statement. A statement must be filed by each party and must include:

(A) a brief factual outline of the case;

(B) the basis for federal jurisdiction and for venue in the division;

(C) the factual basis of each claim or defense advanced by the party;

(D) the legal theory underlying each claim or defense, including, where necessary to a reasonable understanding of the claim or defense, citations to authority;

(E) a computation of damages;

(F) the pendency or disposition of any related state or federal litigation;

(G) proposed additional stipulations of fact not included in the Statement of Stipulated Facts, see L.R. 16.2(b)(3), and the parties' understanding as to what law applies;

(H) proposed deadlines relating to joinder of parties or amendment of the pleadings;

(I) identification of controlling issues of law suitable for pretrial disposition;

(J) the name and city and state of current residence of each individual known or believed to have information that may be used in proving or denying any party's claims or defenses, and a summary of that information. If known, the address and telephone number of the individual must be provided to all counsel on request;

(K) the substance of any insurance agreement that may cover any resulting judgment;

(L) the status of any settlement discussions and prospects for compromise of the case; and

(M) suitability of special procedures.

(2) Discovery Plan.

(A) In addition to the matters set forth in Fed. R. Civ. P. 26(f), the parties must identify likely areas of expert testimony.

(B) Plaintiff must file on behalf of all parties the discovery plan resulting from the Rule 26(f) conference.

(3) Statement of Stipulated Facts. Plaintiff must separately file a Statement of Stipulated Facts to which all parties agree.