EXHIBIT A
PROPOSED SCHEDULE OF PRETRIAL AND TRIAL DATES
Weeks Before Plaintiff(s) Defendant(s)
Matter1 Trial Request Request
Court Order
Approx. 30
days after entry
of the Case
Deadline to file Motion to
Management
Join Parties
and Scheduling
Order absent
good cause
Approx. 30
days after entry
Deadline to Serve All Parties of the Case
(including DOE or ROE Management
Defendants) and Scheduling
Order absent
good cause
Deadline to file Motion to
40
Amend Pleadings
Fact Discovery Cut-Off
(including filing of related 21
motions)
Expert Disclosures 19
Rebuttal Expert Disclosures 16
Expert Discovery Cut-Off
(including filing of related 14
motions)
Substantive Motions
13
10:00 a.m. (Weds.)
L.R. 16−14 L.R. 16−14 L.R. 16−14
Settlement Settlement Settlement
Choice: Choice: Choice:
☐ No. 1 ☐ No. 1 ☐ No. 1
Last Day to Conduct USMJ USMJ USMJ
Settlement Proceedings 12 ☐ No. 2 Court ☐ No. 2 Court ☐ No. 2 Court
Mediation Mediation Mediation
Panel Panel Panel
☐ No. 3 Private ☐ No. 3 Private ☐ No. 3 Private
ADR ADR ADR
Date: Date: Date:
Last Day to File Motions
in Limine and Daubert 8
Motions
Final Pretrial Conference
2
2:00 p.m. (Weds.)
☐ Jury ☐ Jury ☐ Jury
Trial Date ☐ Bench ☐ Bench ☐ Bench
9:00 a.m. (Tues.) Est. length: Est. length: Est. length:
Date: _____ Date: _____ Date: _____
1 The parties should seek additional deadlines relevant to the specific case type at issue by including them in their
Joint 26(f) Report. For example, class action, ERISA, and patent cases may need to vary from the above.
