UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF TEXAS
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Plaintiff, '
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vs. ' CIVIL ACTION NO.
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Defendant, '
JOINT DISCOVERY/ CASE MANAGEMENT PLAN
UNDER RULE 26(f)
FEDERAL RULES OF CIVIL PROCEDURE
Please restate the instruction before furnishing the information.
1. State when the parties conferred as required by Rule 26(f), and identify the counsel who
conferred.
2. List the cases related to this one that are pending in any state or federal court with the case
number and court.
3. Briefly describe what the case is about.
4. Specify the allegation of federal jurisdiction.
5. Name the parties who disagree and the reasons.
6. List anticipated additional parties that should be included, when they can be added, and by
whom they are wanted.
7. List anticipated interventions.
8. Describe class-action issues.
9. State whether each party represents that it has made the initial disclosures required by Rule
26(a). If not, describe the arrangements that have been made to complete the disclosures.
10. Describe the proposed agreed discovery plan, including:
A. Responses to all the matters raised in Rule 26(f).
B. When and to whom the plaintiff anticipates it may send interrogatories.
C. When and to whom the defendant anticipates it may send interrogatories.
D. Of whom and by when the plaintiff anticipates taking oral depositions.
E. Of whom and by when the defendant anticipates taking oral depositions.
F. When the plaintiff (or the party with the burden of proof on an issue) will be able
to designate experts and provide the reports required by Rule 26(a)(2)(B), and
when the opposing party will be able to designate responsive experts and provide
their reports.
G. List expert depositions the plaintiff (or the party with the burden of proof on an
issue) anticipates taking and their anticipated completion date. See Rule
26(a)(2)(B) (expert report).
H. List expert depositions the opposing party anticipates taking and their anticipated
completion date. See Rule 26(a)(2)(B) (expert report).
11. If the parties are not agreed on a part of the discovery plan, describe the separate views and
proposals of each party.
12. Specify the discovery beyond initial disclosures that has been undertaken to date.
13. State the date the planned discovery can be reasonably completed.
14. Describe the possibilities for a prompt settlement or resolution of the case that were
discussed in your Rule 26(f) meeting.
15. Describe what each party has done or agreed to do to bring about a prompt resolution.
16. From the attorneys= discussion with the client, state the alternative dispute resolution
techniques that are reasonably suitable, and state when such a technique may be effectively
used in this case.
17. Magistrate judges may now hear jury and non-jury trials. Indicate the parties= joint
position on a trial before a magistrate judge.
18. State whether a jury demand has been made and if was made on time.
19. Specify the number of hours it will take to present the evidence in this case.
20. List pending motions that could be ruled on at the initial pretrial and scheduling
conference.
21. List other motions pending.
22. Indicate other matters peculiar to this case, including discovery, that deserve the special
attention of the court at the conference.
23. Certify that all parties have filed Disclosure of Interested Parties as directed in the Order
for Conference and Disclosure of Interested Parties, listing the date of filing for original
and any amendments.
24. List the names, bar numbers, addresses and telephone numbers of all counsel.
_______________________________ ____________________________
Counsel for Plaintiff(s) Date
________________________________ ____________________________
Counsel for Defendant(s) Date
