Joint Proposed Discovery Plan (Rule 16) {NJD JPDP}

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY ____________________________________ : : Civil Action No. : Plaintiff(s) : Hon. : : v. : JOINT PROPOSED DISCOVERY PLAN : : : Defendant(s) : : ____________________________________: 1. Set forth the name of each attorney appearing, the firm name, address and telephone number and facsimile number of each, designating the party represented. Set forth a brief description of the case, including the causes of action and defenses asserted. Have settlement discussions taken place? Yes __________ No __________ (a) What was plaintiff's last demand? (1) (2) (b) Monetary demand: $ ___________ Non-monetary demand: __________ 2. 3. What was defendant's last offer? (1) (2) Monetary offer: $ ___________ Non-monetary offer: __________ 4. The parties [have __________ have not __________] met pursuant to Fed. R. Civ. P. 26(f): 1 American LegalNet, Inc. www.FormsWorkFlow.com 5. The parties [have ______ have not ______ ] exchanged the information required by Fed. R. Civ. P. 26(a)(1). If not, state the reason therefor. Explain any problems in connection with completing the disclosures required by Fed R. Civ. P. 26(a)(1) The parties [have __________ have not __________] conducted discovery other than the above disclosures. If so, describe. Proposed joint discovery plan: (a) (b) Discovery is needed on the following subjects: Discovery [should __________ should not __________] be conducted in phases or be limited to particular issues. Explain. Proposed schedule: (1) Fed. R. Civ. P. 26 Disclosures . . 6. 7. 8. (c) (2) E-Discovery conference pursuant to L. Civ. R. 26.1(d) (3) Service of initial written discovery . (4) Maximum of _____ Interrogatories by each party to each other party. (5) Maximum of _____ depositions to be taken by each party. (6) Motions to amend or to add parties to be filed by ____________. (7) Factual discovery to be completed by (8) Plaintiff's expert report due on (9) Defendant's expert report due on (10) Expert depositions to be completed by . . . . (11) Dispositive motions to be served within ______days of completion of discovery. (d) Set forth any special discovery mechanism or procedure requested. 2 American LegalNet, Inc. www.FormsWorkFlow.com (e) (f) A pretrial conference may take place on . Trial date: ______________________ (______Jury Trial; _____ Non-Jury Trial). 9. Do you anticipate any special discovery needs (i.e., videotape/telephone depositions, problems with out-of-state witnesses or documents, etc)? Yes _______No_______. If so, please explain. Do you anticipate any issues about disclosure or discovery of electronically stored information, including the form or forms in which it should be produced? Yes _______ No _______. If so, how will electronic discovery or data be disclosed or produced? Describe any agreements reached by the parties regarding same, including costs of discovery, production, related software, licensing agreements, etc. 10. 11. Do you anticipate entry of a Discovery Confidentiality Order? See L.Civ.R. 5.3(b) and Appendix S. Do you anticipate any discovery problem(s) not listed above? Describe. Yes ________ No _______. State whether this case is appropriate for voluntary arbitration (pursuant to Local Civil Rule 201.1 or otherwise) or mediation (pursuant to Local Civil Rule 301.1 or otherwise). If not, explain why and state whether any such procedure may be appropriate at a later time (i.e., after exchange of pretrial disclosures, after completion of depositions, after disposition or dispositive motions, etc.). Is this case appropriate for bifurcation? Yes __________ No __________ An interim status/settlement conference (with clients in attendance), should be held in _______________________________________. We [do __________ do not __________] consent to the trial being conducted by a Magistrate Judge. Identify any other issues to address at the Rule 16 Scheduling Conference. 12. 13. 14. 15. 16. 17. Attorney(s) for Plaintiff(s) / Date Attorney(s) for Defendant(s) / Date 3 American LegalNet, Inc. www.FormsWorkFlow.com