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LOCAL RULE 26.1 OUTLINE FOR FED.R.CIV.P. 26(f) REPORT The Fed.R.Civ.P. 26(f) report filed with the court must contain the parties' views and proposals regarding the following:

(1) Any changes in timing, form, or requirements of mandatory disclosures under Fed.R.Civ.P. 26(a).

(2) Date when mandatory disclosures were or will be made.

(3) Subjects on which discovery may be needed.

(4) Whether any party will likely be requested to disclose or produce information from electronic or computer-based media. If so: (a) whether disclosure or production will be limited to data reasonably available to the parties in the ordinary course of business; (b) the anticipated scope, cost and time required for disclosure or production of data beyond what is reasonably available to the parties in the ordinary course of business; (c) the format and media agreed to by the parties for the production of such data as well as agreed procedures for such production; (d) whether reasonable measures have been taken to preserve potentially discoverable data from alteration or destruction in the ordinary course of business or otherwise; (e) other problems which the parties anticipate may arise in connection with electronic or computer-based discovery.

(5) Date by which discovery should be completed.

(6) Any needed changes in limitations imposed by the Federal Rules of Civil Procedure.

(7) Any orders, e.g. protective orders, which should be entered.

(8) Any objections to initial disclosures on the ground that mandatory disclosures are not appropriate in the circumstances of the action.

(9) Any objections to the proposed trial date.

(10) Proposed deadline for joining other parties and amending the pleadings.

(11) Proposed deadline for completing discovery. (Note: In the typical case, the deadline for completing discovery should be no later than sixty (60) days before trial.)

(12) Proposed deadline for filing motions other than motions for class certification. (Note: In the typical case, the deadline for filing motions should be no later than sixty (60) days before trial.)

(13) Class certification: In the case of a class action complaint, the proposed deadline for the parties to file a motion for class certification. (Note: In the typical case, the deadline for filing motions for class certification should be no later than ninety (90) days after the Fed.R.Civ.P. 26(f) conference.)

Effective December 1, 2000. Amended and effective May 1, 2002