Local Rule LR 16.3: RULE 26(f) REPORT (FORM)

LR 16.3 RULE 26(f) REPORT (FORM)

If the parties are unable to agree on a discovery plan, each party shall file a separate report in substantially the following form:

Rule 26(f) Report 1. Pursuant to Fed.R.Civ.P. 26(f) and LR16.1(b), a meeting was held on date at place and was attended by for Plaintiff(s), and for Defendant(s).

2. Discovery Plan. The undersigned party proposes to the Court the following discovery plan: If there is a pending dispositive motion: Discovery should/should not be postponed or limited pending determination of a pending dispositive motion. The "commencement date" of discovery will be: [a date certain; upon entry of this Order; upon entry of the Court's Order denying a pending dispositive motion in whole or in part]; Discovery will be needed on the following subjects: (brief descriptions) .

Discovery shall be placed on a case-management track established in LR 26.1. The undersigned party proposes that the appropriate plan for this case (with any stipulated modification by the parties as set out below) is that designated in LR 26.1(a) as: Standard Complex Exceptional The date for the completion of all discovery (general and expert) is: . Stipulated modifications to the case management track include: . Reports required by Rule 26(a)(2)(B) and disclosures required by Rule 26(a)(2)(C) are due during the discovery period: From Plaintiff(s) by . From Defendant(s) by . Supplementations will be as provided in Rule 26(e) or as otherwise ordered by the court.

3. Mediation. [For cases selected for mediation under LR 16.4 and LR 83.9a-g et seq.] Mediation should be conducted [early][midway] [late] in the discovery period, the exact date to be set by the mediator after consultation with the parties. The parties agree that the mediator shall be (identity) . (If the parties report no agreement, the clerk will select a mediator from the Court's panel of mediators.)

4. Preliminary Deposition Schedule. The undersigned proposes the following schedule for depositions: . The parties will update this schedule at reasonable intervals.

5. Other items. Plaintiff(s) should be allowed until date to request leave to join additional parties or amend pleadings. Defendant(s) should be allowed until date to request leave to join additional parties or amend pleadings. After these dates, the Court will consider, inter alia, whether the granting of leave would delay trial.

The parties have discussed special procedures for managing this case, including reference of the case to a Magistrate Judge on consent of the parties under 28 U.S.C. §§636(c), or appointment of a master: (Report any agreements on these matters) .

Trial of the action is expected to take approximately days. A jury trial [has][has not] been demanded.

The parties discussed whether the case will involve the possibility of confidential or sealed documents. __ The parties agreed that no documents in this case will be designated as confidential or filed under seal. OR __ The case may involve confidential or sealed documents and the parties have separately filed a LR 5.5 Report.

The basis of federal subject matter jurisdiction is: [federal question] [diversity] [other]. If diversity, the parties have reviewed the Federal Rule 7.1 and Local Rule 7.7 disclosures to confirm diversity, including citizenship of all members of an LLC and partners of a partnership.

Date: Signatures of party or counsel