Local Rule LR 26-1: DISCOVERY PLANS AND MANDATORY DISCLOSURES

LR 26-1. DISCOVERY PLANS AND MANDATORY DISCLOSURES

(a) Discovery Plan. Unless the court orders otherwise, the parties must, within 30 days after all defendants have appeared or been served, submit a proposed discovery plan in the form prescribed by the court. The discovery plan must:

(1) State the date the plan is submitted;

(2) State the dates of service of the parties' initial disclosures;

(3) Contain the proposed discovery cutoff date;

(4) Contain the proposed date by which amendments to the pleadings and joinder of additional parties will be completed;

(5) Contain the proposed date by which all expert disclosures will be completed under Fed. R. Civ. P. 26(a)(2);

(6) Contain the proposed date by which all dispositive motions will be filed;

(7) Contain the proposed date for submission of the joint pretrial order;

(8) Briefly describe the subjects on which discovery may be needed and the nature of the discovery that has been or will be conducted;

(9) State whether the parties agree to electronic service and whether the parties have stipulated to the use of electronic signatures;

(10) Identify any related cases pending in this district;

(11) Describe any other orders the parties request the court enter under Fed. R. Civ. P. 26(c) or 16(b) and (c);

(12) State the date by which the parties will file any motion for class certification;

(13) State whether the parties plan to submit the case to mediation or some other form of alternative dispute resolution and, if so, the date by which they expect to complete the process.

(b) Mandatory Initial Disclosures. Unless the court orders otherwise or the parties agree otherwise in writing, mandatory initial disclosures must be exchanged within 14 days of entry of the scheduling order.

(c) Discovery Completion Date. Unless the court orders otherwise, all discovery must be completed no later than 180 days after the first defendant answers or appears. "Completed" means that all discovery must be initiated a sufficient time in advance to be completed by the deadline. If either party determines that discovery will not be completed within the established deadline, the party must seek an extension well in advance of the deadline in accordance with LR IA 6-1.