Proposed Case Management Order {JDF 622SC}

Page 1 of 4 JDF 622 SC 5/ 1 8 PROPOSED CASE MANAGEMENT ORDER Page 1 of 4 District Court County, Colorado Court Address: COURT USE ONLY Plaintiff(s): v. Defendant(s): Case Number: Division Courtroom PROPOSED CASE MANAGEMENT ORDER Pursuant to C.R.C.P. 16(b), the parties should discuss each item below. If they agree, the agreement should be stated. If they cannot agree, each party should state its position briefly. If an item does not apply, it should be identified as not applicable. This form shall be submitted to the court in editable format. When approved by the court, it shall constitute the Case Management Order for this case unless modified by the court upon a showing of good cause. This form must be filed with the court no later than 42 days after the case is at issue and at least 7 days before the date of the case management conference. The case management conference is set for , 20 at : .m. 1. . 2. 3. The lead counsel for each party, , and any party not represented by counsel, , met and conferred in person or by telephone concerning this Proposed Order and each of the issues listed in Rule 16(b) (3)(A) through (E) on , 20 . 4. Brief description of the case and identification of the issues to be tried (not more than one page, double - spaced, for each side): 5. T he following motions have been filed and are unresolved: 6. listed in C.R.C.P. 26(b)(1): American LegalNet, Inc. www.FormsWorkFlow.com Page 2 of 4 JDF 622 SC 5/ 1 8 PROPOSED CASE MANAGEMENT ORDER Page 2 of 4 7. The lead counsel for each party, , and any party not represented by counsel, , met and conferred concerning possible settlement. The prospects for settlement are: 8. Deadlines for: a. Amending or supplementing pleadings: (Not more than 105 days (15 weeks) from at issue date.) b. Joinder of additional parties: (Not more than 105 days (15) weeks from at issue date. ) c. Identifying non - parties at fault: 9. Dates of initial disclosures: Objections, if any, about their adequacy: 10. provide it, provide a brief state , and completion of discovery on damages: 11. Proposed limita tions on and modifications to the scope and types of discovery, consistent with the proportionality factors in C.R.C.P. 26(b)(1): Number of depositions per party (C.R.C.P. 26(b)(2)(A) limit 1 of adverse part y + 2 others + experts per C.R.C.P. 26(b)(4)(A)): Number of interrogatories per party (C.R.C.P. 26(b)(2)(B) limit of 30): Number of requests for production of documents per party (C.R.C.P. 26(b)(2)(D) limit of 20): Number of requests for admission per party (C.R.C.P. 26(b)(2)(E) limit of 20): Any physical or mental examination per C.R.C.P. 35: Any limitations on awardable costs: State the justifications for any modifications in the foregoing C.R.C.P. 26(b)(2) l imitations: 12. Number of experts, subjects for anticipated expert testimony, and whether experts will be under C.R.C.P. 26(a)(2)(B)(I) or (B)(II): If more than one expert in any subject per side is anticipated, state the reasons why such expert is appropriate consistent with proportionality factors in C.R.C.P. 26(b)( 1) and any differences among the positions of multiple parties on the same side: 13. Proposed deadlines for expert witness disclosure if other than those in C.R.C.P. 26( a)(2): American LegalNet, Inc. www.FormsWorkFlow.com Page 3 of 4 JDF 622 SC 5/ 1 8 PROPOSED CASE MANAGEMENT ORDER Page 3 of 4 a. production of expert reports: i. Plaintiff/claimant: ii. Defendant/opposing party: b. production of rebuttal expert reports: c. production of expert witness files: State the reasons for any different dates from those in C.R.C.P. 26(a)(2)(C): 14. Oral Discovery Motions. The court (does)(does not) require discovery motions to be presented orally, without written motions or briefs. 15. Electronically Stored Information. The parties (do)(do not) anticipate needing to discover a significant amount of electronically stored information. The following is a brief report concerning t heir agreements or positions on search terms to be used, if any, and relating to the production, continued preservation, and restoration of electronically stored information, including the form in which it is to be produced and an estimate of the attendant costs. 16. Trial will commence on (or will be set by the court later): 17. Other appropriate matters for consideration: By checking this box, I am acknowledging I am filling in the blanks and not changing anything else on the form. By checking this box, I am acknowledging that I have made a change to the or i ginal content of this form. SIGNATURE (Printed Signature of Plaintiff) Signature of Plaintiff Date Signature of Attorney (if any) SIGNATURE (Printed Signature of Defendant) Signature of Defendant Date Signature of Attorney (if any) American LegalNet, Inc. www.FormsWorkFlow.com Page 4 of 4 JDF 622 SC 5/ 1 8 PROPOSED CASE MANAGEMENT ORDER Page 4 of 4 CASE MANAGEMENT ORDER IT IS HEREBY ORDERED that the foregoing, including any modifications made by the court, is and shall be the Case Management Order in this case. Dated this day of , 20. BY THE COURT: District Court Judge American LegalNet, Inc. www.FormsWorkFlow.com