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Mark:
Proceeding No.:
Deadlines:
Discovery Conference must be conduct by
Discovery opens
In conferring, the parties must consider the following:
the nature of and basis for their respective claims and defenses;
the possibility of settling the case or at least narrowing the scope of the claims or
defenses;
whether the parties wish to seek mediation, arbitration or some other means for resolving
the dispute; and
If the parties chose to proceed with the disclosure, discovery and trial procedures that govern the
case, then the parties must discuss:
Discovery Limitations:
Proposed deadline for completion of non-expert discovery (including service and response to
interrogatories, document requests, requests for admission and scheduling of factual
depositions):
__________________________
§2.120(a)(3) Initial disclosures - A party must make its initial disclosures prior to seeking
discovery, absent modification of this requirement by a stipulation of the parties approved
by the Board, or a motion granted by the Board, or by order of the Board.
Discovery Plan1
A discovery plan must state the parties’ views and proposals on:
what changes should be made in the timing, form, or requirement for disclosures under
Rule 26(a), including a statement of when initial disclosures were made or will be made;
the subjects on which discovery may be needed, when discovery should be completed,
and whether discovery should be conducted in phases or be limited to or focused on
particular issues;
what changes should be made in the limitations on discovery imposed under these rules
or by local rule, and what other limitations should be imposed; and
1
The parties do not have to file a disclosure/discovery plan with the Board, following their discovery conference,
unless they are seeking leave by motion or stipulation to alter standard deadlines/obligations, or unless they were
directed to make a particular filing by a participating Board professional.
any other orders that the court should issue under Rule 26(c) or under Rule 16(b) and (c).