Joint Status Report And Discovery Plan

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF OKLAHOMA ) ) ) ) ) ) Plaintiff, v. Case No. _____________ Defendant. JOINT STATUS REPORT AND DISCOVERY PLAN Date of Conference: Appearing for Plaintiff: Appearing for Defendant: Jury Trial Demanded - Non-Jury Trial 1. BRIEF PRELIMINARY STATEMENT. State briefly and in ordinary language the facts and positions of the parties to inform the judge of the general nature of the case. JURISDICTION. State the basis on which the jurisdiction of the Court is invoked and any presently known objections. STIPULATED FACTS. List stipulations as to all facts that are not disputed, including jurisdictional facts. CONTENTIONS AND CLAIMS FOR DAMAGES OR OTHER RELIEF SOUGHT. a. b. 5. Plaintiff: Defendant: 2. 3. 4. APPLICABILITY OF FED. R. CIV. P. 5.1 AND COMPLIANCE. Do any of the claims or defenses draw into question the constitutionality of a federal or state statute where notice is required under 28 U.S.C. § 2403 or Fed. R. Civ. P. 5.1? Yes No American LegalNet, Inc. www.FormsWorkFlow.com 6. MOTIONS PENDING AND/OR ANTICIPATED (include date of filing, relief requested, and date responsive brief to be filed). COMPLIANCE WITH RULE 26(a)(1). Have the initial disclosures required by Fed. R. Civ. P. 26(a)(1) been made? Yes No If "no," by what date will they be made? ____________________ PLAN FOR DISCOVERY. A. The discovery planning conference (Fed. R. Civ. P. 26(f)) was held on _______________. The parties anticipate that discovery should be completed within ____ months. In the event ADR is ordered or agreed to, what is the minimum amount of time necessary to complete necessary discovery prior to the ADR session? _______________________. Have the parties discussed issues relating to disclosure or discovery of electronically stored information, including the form or forms in which it should be produced, pursuant to Fed. R. Civ. P. 26(f)(3)(C)? Yes No E. Have the parties discussed issues relating to claims of privilege or of protection as trial-preparation material pursuant to Fed. R. Civ. P. 26(f)(3)(D)? Yes No To the extent the parties have made any agreements pursuant to Fed. R. Civ. P. 26(f)(3)(D) and Fed. R. Civ. P. 502(e) regarding a procedure to assert claims of privilege/protection after production and are requesting that the court include such agreement in an order, please set forth the agreement in detail below and submit a proposed order adopting the same. __________________________________________________________ 7. 8. B. C. D. F. Identify any other discovery issues which should be addressed at the scheduling conference, including any subjects of discovery, limitations on discovery, protective orders needed, or other elements (Fed. R. Civ. P. 26(f)) which should be included in a particularized discovery plan. American LegalNet, Inc. www.FormsWorkFlow.com __________________________________________________________ 9. 10. 11. 12. ESTIMATED TRIAL TIME: ______________ BIFURCATION REQUESTED: Yes No POSSIBILITY OF SETTLEMENT: Good Fair Poor SETTLEMENT AND ADR PROCEDURES: A. B. Compliance with LCvR 16.1(a)(1) - ADR discussion: Yes No The parties request that this case be referred to the following ADR process: Court-Ordered Mediation subject to LCvR 16.3 Judicial Settlement Conference Other _____________________________________________________ None - the parties do not request ADR at this time. 13. 14. Parties consent to trial by Magistrate Judge? Yes No Type of Scheduling Order Requested. Standard - Specialized (If a specialized scheduling order is requested, counsel should include a statement of reasons and proposal.) Submitted this ______ day of _________________. ______________________________________ Counsel for Plaintiff ______________________________________ Counsel for Defendant American LegalNet, Inc. www.FormsWorkFlow.com