Joint Case Management Plan

APPENDIX A Attorneys for Plaintiff Attorneys for Defendant UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA ) CASE NO. ) ) ) ) ) JUDGE ) ) ) ) JOINT CASE MANAGEMENT PLAN Instructions: In many cases there will be more parties in the action than there are spaces provided in this form. Each party shall provide all requested information. If the space on this form is not sufficient, the form should be retyped or additional pages attached. No party may submit a separate Case Management Plan. Disagreements among parties with respect to any of the matters below shall be set forth in the appropriate section. Having complied with the meet and confer requirements set forth in the LOCAL RULES, or with any orders specifically modifying their application in the abovecaptioned matter, the parties hereby submit the following Joint Case Management Plan. (Revised 12/09) 70 American LegalNet, Inc. www.FormsWorkFlow.com 1. Principal Issues 1.1 Separately for each party, please give a statement summarizing this case: By plaintiff(s): By defendant(s): 1.2 The facts the parties dispute are as follows: agree upon are as follows: 1.3 The legal issues the parties dispute are as follows: agree upon are as follows: 1.4 Identify any unresolved issues as to service of process, personal jurisdiction, subject matter jurisdiction, or venue: 1.5 Identify any named parties that have not yet been served: 1.6 Identify any additional parties that: plaintiff(s) intends to join: defendant(s) intends to join: 71 American LegalNet, Inc. www.FormsWorkFlow.com 1.7 Identify any additional claims that: plaintiff(s) intends to add: defendant(s) intends to add: 2.0 Disclosures The undersigned counsel certify that they have made the initial disclosures required by Federal Rule of Civil Procedure 26(a)(1) or that they will do so within the time provided by that rule. 2.1 Separately for each party, list by name and title/position each person whose identity has been disclosed. Disclosed by Name : Title/Position Disclosed by Name : Title/Position 72 American LegalNet, Inc. www.FormsWorkFlow.com 3.0 Early Motions Identify any motion(s) whose early resolution would likely have a significant effect either on the scope of discovery or other aspects of the litigation: Nature of Motion Moving Party Anticipated Filing Date 4.0 Discovery 4.1 Briefly describe any discovery that has been completed or is in progress: By plaintiff(s): By defendant(s): 4.2 Describe any discovery that all parties agree should be conducted, indicating for each discovery undertaking its purpose or what kinds of information will be developed through it (e.g., "plaintiff will depose Mr. Jones, defendant's controller, to learn what defendant's revenue recognition policies were and how they were applied to the kinds of contracts in this case"): 4.3 Describe any discovery that one or more parties want(s) to conduct but to which another party objects, indicating for each such discovery undertaking its purpose or what kinds of information would be developed through it: 4.4 Identify any subject area limitations on discovery that one or more parties would like imposed, at the first stage of or throughout the litigation: 4.5 For each of the following discovery tools, recommend the per-party or perside limitation (specify a number) that should be fixed, subject to later modification by stipulation or court order on an appropriate showing (where the parties cannot agree, set forth separately the limits . recommended by plaintiff(s) and by defendant(s)): 4.5.1 depositions (excluding experts) to be taken by: 73 American LegalNet, Inc. www.FormsWorkFlow.com plaintiff(s): defendant(s): 4.5.2 interrogatories to be served by: plaintiff(s): defendant(s): 4.5.3 document production requests to be served by: plaintiff(s): defendant(s): 4.5.4 requests for admission to be served by: plaintiff(s): 4.6 defendant(s): Discovery of Electronically Stored Information 9 Counsel certify that they have conferred about the matters addressed in M.D. Pa LR 26.1 and that they are in agreement about how those matters will be addressed in discovery. 9 Counsel certify that they have conferred about the matters addressed in M.D. Pa. LR 26.1 and that they are in agreement about how those matters will be addressed in discovery with the following exceptions: 5.0 Protective Order 5.1 If entry of a protective order is sought, attach to this statement a copy of the proposed order. Include a statement justifying the propriety of such a protective order under existing Third Circuit precedent. If there is a dispute about whether a protective order should be entered, or about certain terms of the proposed order, briefly summarize each party's position below: 5.2 6.0 Scheduling 6.1 Final date for joining additional parties: Plaintiff(s) Defendants(s) 6.2 Final date for amending pleadings: Plaintiff(s) Defendants(s) 74 American LegalNet, Inc. www.FormsWorkFlow.com 6.3 All fact discovery commenced in time to be completed by: ________________ All potentially dispositive motions should be filed by: Reports from retained experts due: from plaintiff(s) by from defendant(s) by 6.4 6.5 6.6 6.7 6.8 Supplementations due All expert discovery commenced in time to be completed by This case may be appropriate for trial in approximately: 240 Days from the filing of the action in this court 365 Days from the filing of the action in this court Days from the filing of the action in this court 6.9 Suggested Date for the final Pretrial Conference: (month/year) 6.10 Trial 6.10.1 Suggested Date for Trial: (month/year) 7.0 Certification of Settlement Authority (All Parties Shall Complete the Certification) I hereby certify that the following individual(s) have settlement authority. Name Title Address () Daytime Telephone 75 American LegalNet, Inc. www.FormsWorkFlow.com Name Title Address () 8.0 Daytime Telephone Alternative Dispute Resolution ("ADR") 8.1 Identify any ADR procedure to which this case already has been assigned or which the parties have agreed to use. ADR procedure Date ADR to be commenced Date ADR to be completed 8.2 If the parties have been unable to agree on an ADR procedure, but one or more parties believes that the case is appropriate for such a procedure, identify the party or parties that recommend ADR and the specific ADR process recommended: 8.3 If all parties share the view that no ADR procedure should be used in this case, set forth the basis for that view: 9.0 Consent to Jurisdiction by a Magi