Form 35 Fed.R.Civ.P.

Report of Parties Planning Meeting


[Caption and Names of Parties]

1. Pursuant to Fed.R.Civ.P. 26(f), a meeting was held on  (date)  at   (place)  and was attended by:

  (name)  for plaintiff(s)
  (name)  for defendant(s)   (party name) 
  (name) 
for defendant(s)   (party name) 

2. Pre-Discovery Disclosures.  The parties [have exchanged] [will exchange by   (date)  ] the information required by [Fed.R.Civ.P. 26(a)(1)] [local rule      ].

3. Discovery Plan.  The parties jointly propose to the court the following discovery plan: [Use separate paragraphs or subparagraphs as necessary if parties disagree.]

Discovery will be needed on the following subjects: (brief description of subjects on which discovery will be needed)

All discovery commenced in time to be completed by   (date)  .  [Discovery on   (issue for early discovery)  to be completed by   (date)  .]

Maximum of        interrogatories by each party to any other party.  [Responses due      days after service.]

Maximum of        requests for admission by each party to any other party.  [Responses due      days after service.]

Maximum of        depositions by plaintiff(s) and        by defendant(s).
Each deposition [other than of               ] limited to maximum of      hours unless extended by agreement of parties.

Reports from retained experts under Rule 26(a)(2) due:
from plaintiff(s) by   (date) 
from defendant(s) by   (date) 

Supplementations under Rule 26(e) due (time(s) or interval(s)) .

4. Other Items.  [Use separate paragraphs or subparagraphs as necessary if parties disagree.]

The parties [request] [do not request] a conference with the court before entry of the scheduling order.

The parties request a pretrial conference in (month and year) .

Plaintiff(s) should be allowed until    (date)  to join additional parties and until   (date)  to amend the pleadings.

Defendant(s) should be allowed until    (date)  to join additional parties and until    (date)  to amend the pleadings.

All potentially dispositive motions should be filed by    (date) 

Settlement [is likely] [is unlikely] [cannot be evaluated prior to    (date)  ] [may be enhanced by use of the following alternative dispute resolution procedure: [                 ].

Final lists of witnesses and exhibits under Rule 26(a)(3) should be due:
from plaintiff(s) by   (date) 
from defendant(s) by    (date) 

Parties should have      days after service of final lists of witnesses and exhibits to list objections under Rule 26(a)(3).

The case should be ready for trial by   (date)   [and at this time is expected to take approximately   (length of time)].

[Other matters]

Date:           

/signed by all counsel