Joint Status Report And Provisional Discovery Plan

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO ___________________________________, Plaintiff, vs. ___________________________________, Defendant. CIVIL NO. _____________________ JOINT STATUS REPORT AND PROVISIONAL DISCOVERY PLAN Pursuant to FED. R. CIV. P. 26(f), a meeting was held on ________________________ at ______________________________ and was attended by: __________________________ for Plaintiff(s) __________________________ for Defendant(s) __________________________ for other parties. NATURE OF THE CASE AMENDMENTS TO PLEADINGS AND JOINDER OF PARTIES Plaintiff intends to file: Plaintiff(s) should be allowed until _______________ to move to amend the pleadings and until __________________ to join additional parties in compliance with the requirements of Fed. R. Civ. P. 15(a). Defendant intends to file: Defendants(s) should be allowed until _______________ to move to amend the pleadings and until __________________ to join additional parties in compliance with the requirements of Fed. R. Civ. P. 15(a). Version 3: December 2009 American LegalNet, Inc. www.FormsWorkFlow.com STIPULATIONS The parties hereto stipulate and agree that venue is properly laid in this District; that the United States District Court for the District of New Mexico has jurisdiction of the parties and the subject matter. The parties are willing to further stipulate to the following facts: The parties further stipulate and agree that the law governing this case is: PLAINTIFF'S CONTENTIONS: DEFENDANT'S CONTENTIONS PROVISIONAL DISCOVERY PLAN The parties jointly propose to the Court the following discovery plan: (Use separate paragraphs or subparagraphs as necessary if parties disagree.) List all witnesses who, at this time, you think will either testify or be deposed, giving their name, title, address and a brief summary of their testimony. It is insufficient to list witnesses' addresses, save for clients, "in care of counsel." List all documents which you believe, at this time, will be exhibits at the trial. List all experts who you believe, at this time, will testify at the trial, giving their name, address, area of expertise, and a brief summary of the anticipated testimony. Discovery will be needed on the following subjects: (Brief description of subjects on which discovery will be needed.) Maximum of ______ interrogatories by each party to any other party. (Responses due ___________ days after service). Maximum of _______ requests for admission by each party to any other party. (Response due ________ days after service). -2Version 3: December 2009 American LegalNet, Inc. www.FormsWorkFlow.com Maximum of _______ depositions by Plaintiff(s) and ________ by Defendant(s). Each deposition (other than of ___________) limited to maximum of ________ hours unless extended by agreement of parties. Reports from retained experts under Rule 26(a)(2) due: from Plaintiff(s) by ________________________________ from Defendant(s) by ______________________________ Supplementation under Rule 26(e) due _______________________ (set time(s) or interval(s)). All discovery commenced in time to be complete by ___________________. Discovery on (issue for early discovery) to be completed by _____________________. Other Items: (Use separate paragraphs or subparagraphs as necessary if other parties disagree.) PRETRIAL MOTIONS Plaintiff intends to file: Defendant intends to file: ESTIMATED TRIAL TIME The parties estimate trial will require ________________________ days/weeks. ____ This is a non-jury case. ____ This is a jury case. The parties request a pretrial conference in _______________________. -3- Version 3: December 2009 SETTLEMENT The possibility of settlement in this case is considered (likely) (unlikely) (cannot be evaluated prior to ______________) (may be enhanced by use of the following alternative dispute resolution procedure: _________________________). The parties request a settlement conference in _____________________________. EXCEPTIONS (Where counsel cannot agree to any recitation herein, exceptions shall be listed.) APPROVED WITH/WITHOUT EXCEPTIONS (note exceptions above) __________________________________________ For Plaintiff __________________________________________ For Defendant __________________________________________ Other Party -4- Version 3: December 2009