Rule 16b Scheduling Order
United States District Court
For The Northern District of Illinois
Eastern Division
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Plaintiff(s), )
v. ) Case No.:
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) Magistrate Judge Maria Valdez
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Defendant(s). )
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PROPOSED SCHEDULING ORDER
1. Pre-Discovery Conference and Disclosures
A. The parties advise the Court that they have / have not (circle one) had a conference
pursuant to Rule 26(f). The parties affirm their understanding of the requirements under
Rule 26(f) including the requirement to discuss any discovery issues about electronically
stored information (ESI) that may pertain to this case.
B. The parties advise the Court that initial disclosures have / have not (circle one) been
made pursuant to Rule 26(a)(1). If they have not been made all disclosures required by
Rule 26(a)(1) shall be made on or before ________________________.
2. Discovery
The following time limits and deadlines shall be applicable:
A. Any amendments to pleadings or actions to join other parties shall be filed on or before
_____________. (It is recommended that any joinder or amendments be made early in
the discovery process so as to avoid the need to prolong discovery as to new parties or
new issues.)
B. All written discovery shall be propounded no later than 45 days before the close of fact
discovery, unless the requesting party has obtained prior leave of court.
C. The cutoff of fact discovery is ______________.
D. For personal injury cases, the treating physician discovery deadline is ______________.
E. Any party with the burden of proof shall disclose its expert testimony pursuant to Rule
26(a)(2) on or before ______________.
F. The parties may depose the other side's expert disclosed pursuant to Rule 26(a)(2) at any
time prior to ___________.
G. The parties shall disclose any rebuttal expert at any time prior to ______________.
H. The parties shall have until ______________ to depose the opposing party's rebuttal
expert.
3. Prospects of Settlement
A. Counsel are to discuss settlement at the scheduling conference and to report on the status
of settlement discussions.
B. The parties are to report on the earliest date on which they would be prepared to attend a
settlement conference (with clients) with the Court and what discovery, if any, they
believe may be needed to meaningfully assess settlement.
[Sections 4 through 6 to be filled out only if the parties have consented to have the
case tried before Judge Valdez]
4. Motions
A. Any dispositive motions to be filed on or before ______________. (Ordinarily this date
will be 30 days following the close of fact discovery.)
B. Any Daubert motions to be filed on or before _______________. (Ordinarily this date
will be 30 days following the close of expert discovery.)
5. Final Pretrial Order and Conference
A. The final pretrial order shall be filed on or before ______________.
B. The final pretrial conference will be held on ______________ at ________.m.
6. Trial
The case will be ready for trial by ______________ and is expected to take ______trial days.
ENTERED:
Dated: ___________________ ___________________________
HON. MARIA VALDEZ
United States Magistrate Judge
