Currie Consent Amended Scheduling Order

IN THE UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA [DIVISION [ALL CAPS]] DIVISION [Plaintiff] Plaintiff(s), v. [defendant] Defendant(s). ) ) ) ) ) ) ) ) ) CA: [Case number] CONSENT AMENDED SCHEDULING ORDER Pursuant to the Federal Rules of Civil Procedure and the Local Civil Rules of this Court, the following schedule is established for this case. 1. Motions to join other parties and amend the pleadings (Fed. R. Civ. P. 16(b)(1)) shall be filed no later than [join/amend date]. Plaintiff(s) shall file and serve a document identifying by full name, address, and telephone number each person whom Plaintiff(s) expects to call as an expert at trial and certifying that a written report prepared and signed by the expert including all information required by Fed. R. Civ. P. 26(a)(2)(B) has been disclosed to other parties by [Plaintiff ID of Expert Witness date]. Defendant(s) shall file and serve a document identifying by full name, address, and telephone number each person whom Defendant(s) expects to call as an expert at trial and certifying that a written report prepared and signed by the expert including all information required by Fed. R. Civ. P. 26(a)(2)(B) has been disclosed to other parties by [Defendant ID of Expert Witness date]. Counsel shall file and serve a document identifying all records custodian witnesses proposed to be presented by affidavit at trial and certifying that appropriate affidavits with attached records have been served on other parties no later than [Records Custodian Affidavit date]. Objections to such affidavits must be made within fourteen (14) days after the service of the disclosure. See Fed. R. Evid. 803(6), 902(11), or 902(12) and Local Civil Rule 16.02(D)(3). Discovery shall be completed no later than [Discovery date]. All discovery requests shall be served in time for the responses thereto to be served by this date. De bene esse depositions must be completed by discovery deadline. No motions relating to discovery shall be filed until counsel have consulted and attempted to resolve the matter as required by Local Civil Rule 7.02, and have had a telephone conference with Judge Currie in an attempt to resolve the matter informally. All motions, except those to complete discovery, those nonwaivable motions made pursuant to Fed. R. Civ. P. 12, and those relating to the admissibility of evidence at trial, shall be filed on or before [Motions date]. (Fed. R. Civ. P. 16(b)(2)). 2. 3. 4. 5. 6. American LegalNet, Inc. www.FormsWorkflow.com 7. Mediation, pursuant to Local Civil Rules 16.04 ­ 16.12, shall be completed in this case on or before [Mediation due date]. See Standing Order to Conduct Mediation 4:00-mc5001, filed December 1, 2000, which sets forth mediation requirements (http://www.scd.uscourts.gov). At least thirty (30) days prior to this mediation deadline, counsel for each party shall file and serve a statement certifying that counsel has: (1) provided the party with a copy of Standing Order 4:00-mc-5001; (2) discussed the availability of mediation with the party; and (3) discussed the advisability and timing of mediation with opposing counsel. No later than [Rule 26(a)(3) Disclosures date] the parties shall file and exchange Fed. R. Civ. P. 26(a)(3) pretrial disclosures. Within fourteen (14) days thereafter, a party shall file and exchange Fed. R. Civ. P. 26(a)(3) objections, any objections to use of a deposition designated by another party and any deposition counter-designations under Fed. R. Civ. P. 32(a)(4). See Local Civil Rule 30.03(J) (video deposition additional requirements). Motions in limine must be filed by [Motions in Limine date]. Parties shall furnish the Court pretrial briefs five (5) business days prior to the date set for jury selection (Local Civil Rule 26.05).1 Attorneys shall meet at least five (5) business days prior to the date set for submission of pretrial briefs for the purpose of exchanging and marking all exhibits. See Local Civil Rule 26.07. This case is subject to being called for jury selection and trial on or after [Jury Selection date]. 8. 9. 10. 11. The parties' attention is directed to the Notice of Availability of United States Magistrate Judge to Exercise Jurisdiction. A copy of the form is available in the Clerk's office or at the Court's internet site at http://www.scd.uscourts.gov under Judge Currie's forms. ______________________________ Cameron McGowan Currie United States District Judge Dated: ______________________ Columbia, South Carolina Judge Currie requires that pretrial briefs be filed with the Clerk of Court as part of the public record and served on opposing parties. 1 American LegalNet, Inc. www.FormsWorkflow.com