Agreement For Individualized Trial And Request For Approval

1 2 3 4 5 6 7 NAME, 8 9 v. Plaintiff, Case No. AGREEMENT FOR INDIVIDUALIZED TRIAL AND REQUEST FOR APPROVAL Defendant. The parties agree that all litigation in the above captioned matter shall be governed by UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 10 NAME, 11 12 13 Local Civil Rule 39.2, "the Individualized Trial Procedure," unless otherwise ordered by the 14 court. This agreement, when approved by the court, shall be binding on the parties. 15 In addition to the terms set forth in Local Civil Rule 39.2, the parties elect and agree to 16 the following: 17 1. The judge may order equitable relief consistent with and within the options agreed to by the 18 parties, e.g., injunctive relief, promises to implement policies or practices, etc. 19 2. The parties agree to further reduce the scope of the litigation and the trial in the following 20 ways (e.g., to forego pretrial motions, such as motions to dismiss, motions for summary 21 judgments, etc., in exchange for limitations on damages, including waiver of punitive damages): 22 ____________________________________________________________________________. 23 3. The pretrial conference and pretrial order obligations in LCR 16 will be reduced or amended as follows:_________________________________________________________________. AGREEMENT FOR INDIVIDUALIZED TRIAL AND REQUEST FOR APPROVAL-1 American LegalNet, Inc. www.FormsWorkFlow.com 1 4. Other:_______________________________________________________. 2 The parties agree that any and all rights to appeal from any judgment in this matter are 3 waived by all parties, except as provided in LCR 39.2. 4 5 6 7 By: /s/ Name NAME ATTORNEYS FOR PLAINTIFF By: /s/ Name NAME ATTORNEYS FOR DEFENDANT DATED: _______________, 20__. 8 IT IS ORDERED that the forgoing agreement is approved. The Court will issue an 9 individualized trial schedule consistent with this order. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 NAME United States District Judge [or United States Magistrate Judge] DATED this ______ day of _________, 20__. AGREEMENT FOR INDIVIDUALIZED TRIAL AND REQUEST FOR APPROVAL-2 American LegalNet, Inc. www.FormsWorkFlow.com