§ Form 52 Report of the Parties' Planning Meeting

Form 52. Report of the Parties' Planning Meeting

(Caption--See Form 1.)

1. The following persons participated in a Rule 26(f) conference on date by state the method of conferring :

2. Initial Disclosures. The parties [have completed] [will complete by date ] the initial disclosures required by Rule 26(a)(1).

3. Discovery Plan. The parties propose this discovery plan:

(Use separate paragraphs or subparagraphs if the parties disagree.)

(a) Discovery will be needed on these subjects: (describe)

(b) Disclosure or discovery of electronically stored information should be handled as follows: (briefly describe the parties' proposals, including the form or forms for production.)

(c) The parties have agreed to an order regarding claims of privilege or of protection as trial-preparation material asserted after production, as follows: (briefly describe the provisions of the proposed order.)

(d) (Dates for commencing and completing discovery, including discovery to be commenced or completed before other discovery.)

(e) (Maximum number of interrogatories by each party to another party, along with dates the answers are due.)

(f) (Maximum number of requests for admission, along with the dates responses are due.)

(g) (Maximum number of depositions for each party.)

(h) (Limits on the length of depositions, in hours.)

(i) (Dates for exchanging reports of expert witnesses.)

(j) (Dates for supplementations under Rule 26(e).)

4. Other Items:

(a) (A date if the parties ask to meet with the court before a scheduling order.)

(b) (Requested dates for pretrial conferences.)

(d) (Final dates for the defendant to amend pleadings or to join parties.)

(e) (Final dates to file dispositive motions.)

(f) (State the prospects for settlement.)

(g) (Identify any alternative dispute resolution procedure that may enhance settlement prospects.)

(h) (Final dates for submitting Rule 26(a)(3) witness lists, designations of witnesses whose testimony will be presented by deposition, and exhibit lists.)

(i) (Final dates to file objections under Rule 26(a)(3).)

(j) (Suggested trial date and estimate of trial length.)

(k) (Other matters.)

(Date and sign--see Form 2.)