Trial Scheduling And Discovery Plan {Rule 23.5 Form 2}

Rule 23.5--Form 2: Trial Scheduling and Discovery Plan Do not file this form in an Expedited Civil Action case, instead use Form 3. · · This form is to be filed within 7 days after the parties' discovery conference and before the trial-setting conference with the court. The parties should complete the entire form except as otherwise indicated. In the Iowa District Court for No. County Trial Scheduling and Discovery Plan Plaintiff(s) / Petitioner(s) Full name: first, middle, last Use of this form is mandatory Date Petition filed: mm / dd / yyyy vs. Case type: Law PCR Trial type: Jury Equity Other Judicial Review Nonjury Defendant(s) / Respondent(s). Full name: first, middle, last Expected trial length: days The amount in controversy exceeds $10,000. Yes No Appearances: Plaintiff(s) / Petitioner(s) Defendant(s) / Respondent(s) It is ordered: 1. Trial Note to parties: Unless you have obtained a trial date from court administration, leave this date blank; the court will enter the date after the trial-setting conference. a.m. Trial of this case is set for Month Day , 20 Year , at Time : p.m. in the district court in the courthouse of the county named above. 2. Pretrial conference Check one. Note to parties: If box A is checked, leave the date blank unless you have obtained a pretrial conference date from court administration. If you do not have a pretrial conference date and check box A, the court will enter the date, by order, after the trial-setting conference. a.m. p.m. A. A pretrial conference will be held on , 20 , at : Month Day Year Time The conference may be held telephonically with prior approval of the court. B. A pretrial conference will be held upon request. 3. New parties List the time period or date when no new parties may be added. No new parties may be added later than 180 days before trial or by _________________________. If you need assistance to participate in court due to a disability, contact the disability coordinator at: (_______) __________________ Persons who are hearing or speech impaired may call Relay Iowa TTY (1-800-735-2942). Disability coordinators cannot provide legal advice. Disability coordinator contact information available at: http://www.iowacourts gov/Administration/Directories/ADA_Access/ October 2015 Rule 23.5--Form 2 Page 1 of 6 American LegalNet, Inc. www.FormsWorkFlow.com Rule 23.5--Form 2: Trial Scheduling and Discovery Plan, continued 4. Transcripts and records All required agency records or prior criminal transcripts will be filed within 30 days of the date of this Plan or by _________________________. 5. Pleadings List the time period or date pleadings will be closed. Pleadings will be closed 60 days before trial or by _______________________________________. 6. Initial disclosures Check all that apply A. The parties have exchanged initial disclosures. B. The parties will provide initial disclosures no later than C. The parties have stipulated that the following will not be included in initial disclosures: List items not included . D. The parties have stipulated not to provide any initial disclosures. E. The following party objects to providing initial disclosures on the following grounds: Identify the party and state all applicable grounds 7. Discovery The parties have held a discovery conference as required by Iowa Rule of Civil Procedure 1.507. All written discovery will be served no later than 90 days before trial. All depositions will be completed no later than 60 days before trial. Or, all discovery will be completed by ________________________________________________________________________ Check all that apply A. No discovery of electronically stored information is expected in this case. B. The parties have conferred about discovery of electronically stored information and reached agreement as set out in Attachment . C. The parties have conferred about discovery of electronically stored information and have been unable to reach an agreement. Note to parties: If box C is checked, leave the following information blank unless the parties have obtained a hearing date, time, and location from court administration. a.m. p.m. A hearing is set for / / , at: : mm dd yyyy Time . at the County County Courthouse, courtroom Courtroom number , or . . at the following location: D. The parties have agreed to a discovery plan, and their agreement is set forth in Attachment E. The parties have agreed to deviate from the limits on discovery otherwise applicable to this action, and their agreement is set forth in Attachment . F. The parties have agreed to conduct discovery in phases, and their agreement is set forth in Attachment . October 2015 Rule 23.5--Form 2 Page 2 of 6 American LegalNet, Inc. www.FormsWorkFlow.com Rule 23.5--Form 2: Trial Scheduling and Discovery Plan, continued G. The parties have reached an agreement under Iowa Rule of Evidence 5.502 as set forth in Attachment . H. The parties have reached an agreement under Iowa Rule of Civil Procedure 1.504 as set forth in Attachment . I. The parties have conferred about a discovery plan and have been unable to reach agreement on the issues set forth in Attachment . Note to parties: If box I is checked, leave the following information blank unless the parties have obtained a hearing date, time, and location from court administration. a.m. A hearing is set for mm / dd / yyyy , at: Time : p.m. , or Courtroom number at the County County Courthouse, courtroom at the following location: . 8. Expert witnesses A. A party who intends to call an expert witness, including rebuttal expert witnesses, shall certify to the court and all other parties the expert's name, subject matter of expertise, and qualifications, within the following time period, unless the Iowa Code requires an earlier designation date (see, e.g., Iowa Code section 668.11): (1) (2) (3) Plaintiff: 210 days before trial or by ____________________________________________. Defendant/Third Party Plaintiff: 150 days before trial or by __________________________. Third Party Defendant/Others/Rebuttal: 90 days before trial or by ____________________. B. Any disclosures required by Iowa Rule of Civil Procedure 1.500(2)(b) will be provided: Check each that applies (1) (2) At the same time the expert is certified. According to the following schedule: a. Plaintiff: days before trial or by ________________________________ _______. days before trial or by __________ ________ ___. days before trial or by . b. Defendant/Third Party Plaintiff: c.