ADR SCHEDULING ORDER: Case Management Statement due by 1/3/2011. Case Management Conference set for 1/10/2011 01:30 PM in Courtroom 2, 5th Floor, San Jose. (bw, COURT STAFF) (Filed on 11/14/2011)
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Page 1 ORIG
UNITED STATES DISTRICT COURT i NAL FILED
NORTHERN DISTRICT OF CALIFORNIA Oy 1 4 20
201)
ogilen
Northorn 2, lutea
THINK COMPUTER CORPORATION, San doe Califor i
No. C 11-05496 HRL
Plaintiff (s),
v. ORDER SETTING INITIAL CASE
MANAGEMENT CONFERENCE
ROBERT VENCHIARUTTI, ET AL, AND ADR DEADLINES
Defendant(s).
IT IS HEREBY ORDERED that this action is assigned to the Honorable Howard R. Lloyd.
When serving the complaint or notice of removal, the plaintiff or removing defendant must serve on all
other parties a copy of this order , the Notice of Assignment of Case to a United States
Magistrate Judge for Trial, and all other documents specified in Civil Local Rule 4-2. Counsel must
comply with the case schedule listed below unless the Court otherwise orders.
IT IS FURTHER ORDERED that this action is assigned to the Alternative Dispute Resolution
(ADR) Multi-Option Program governed by ADR Local Rule 3. Counsel and clients shall familiarize
themselves with that rule and with the material entitled “Dispute Resolution Procedures in the Northern
District of California” on the Court ADR Internet site at www.adr.cand.uscourts.gov. A limited
number of printed copies are available from the Clerk’s Office for parties in cases not subject to the
court’s Electronic Case Filing program (ECF).
IT IS FURTHER ORDERED that plaintiff or removing defendant serve upon all parties
the brochure entitled “Consenting To A Magistrate Judge’s Jurisdiction In The Northern
District Of California,” additional copies of which can be downloaded from the following
Internet site: http://www.cand.uscourts.gov.
CASE SCHEDULE -ADR MULTI-OPTION PROGRAM
Date Event Governing Rule
11/14/2011 Complaint filed
12/20/2011 *Last day to: FRCivP 26(f) & ADR
* meet and confer re: initial disclosures, early L.R.3-5
settlement, ADR process selection, and discovery plan
- file ADR Certification signed by Parties and Counsel _—Civil_L.R. 16-8 (b) &
(form available at http://www.cand.uscourts.gov) ADR LR. 3-5(b)
* file either Stipulation to ADR Process or Notice of Civil L.R. 16-8 (c) &
Need for ADR Phone Conference (form available at ADR L.R. 3-5(b) &
http://www.cand.uscourts.gov) (c)Page 2 1/3/2012 Last day to file Rule 26(f) Report, complete initial ERCivP 26(a) (1)
disclosures or state objection in Rule 26(f) Report and file Civil L.R. 16-9
Case Management Statement per attached Standing Order
re Contents of Joint Case Management Statement (also
available at http://www.cand.uscourts.gov)
1/10/2012 INITIAL CASE MANAGEMENT CONFERENCE _ Civil L.R. 16-10
(CMC) in Courtroom 2, Sth Floor SJ at 1:30 PM
*If the Initial Case Management Conference is continued, the other deadlines are continued
accordingly.Page 3 UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
MAGISTRATE JUDGE HOWARD R. LLOYD
STANDING ORDER RE: INITIAL CASE MANAGEMENT
‘In cases that are randomly assigned to Judge Lloyd for all purposes, the parties are
requested to file their written consent to the assignment of a U.S. Magistrate Judge
for all purposes, or their written declination of consent, as soon as possible.
The civil motion calendar is heard on Tuesdays at 10:00 a.m. The criminal motion
calendar is heard on Thursdays at 9:30 a.m. Motions may be noticed for hearing
pursuant to Civil L.R. 7. Counsel need not reserve a hearing date in advance for civil
motions, although noticed dates may be reset as the Court’s calendar requires.
HOWEVER, do not notice a motion over a civil discovery dispute. Instead, follow this
court's “Standing Order re: Civil Discovery Disputes.”
Parties with questions regarding scheduling (excluding settlement conferences)
should contact Judge Lloyd’s Administrative Law Clerk at (408) 535-5411.
A Case Management Conference will be held on the date and time specified in the
Order Setting Initial Case Management Conference in Courtroom 2, United States
Courthouse, 280 South First Street, San Jose, California. This conference may be
continued only by Court Order pursuant to Civil L.R. 16-2(e). Parties may not
stipulate to continue a Case Management Conference without Court approval.
Pursuant to Civil L.R. 16-9, no later than seven (7) days before the Case
Management Conference, the parties shall file a Joint Case Management
Statement. For the required format and contents of this filing, follow the “Standing
Order for All Judges of the Northern District of California: Contents of Joint Case
Management Statement.” If preparation of a joint statement would cause undue
hardship, the parties may serve and file separate statements, which shall include a
description of the undue hardship.
Plaintiff or removing Defendant shall serve a copy of this Standing Order on all
parties to this action and on all parties subsequently joined, in accordance with
Fed.R.Civ.P 4 and 5. Following service, Plaintiff shall file a certificate of service, in
accordance with Civil L.R. 5-6.
IT IS SO ORDERED.
Dated:
August 22, 2002
Amended February 26, 2007
Amended June 3, 2011
HOWARD R. LLOYD
United States Magistrate JudgePage 4 UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
MAGISTRATE JUDGE HOWARD R. LLOYD
STANDING ORDER RE: CIVIL DISCOVERY DISPUTES
1. Effect of Delay on Discovery Disputes.
The parties and counsel are cautioned not to allow discovery disagreements to drag
on unresolved until some important looming deadline forces them into action. Because of
the press of its other business, the court may not be able to give the dispute its attention
with the same celerity that some or all of the parties think is necessary.
2. Resolving Discovery Disputes
In order for this court to efficiently and flexibly respond to discovery disputes, and
accounting both for (1) parties’ and counsels’ obligation to diligently strive to resolve such
disputes without court involvement and (2) the limitations on available judicial resources:
effective immediately this court adopts a new procedure for resolving discovery disputes.
A. Absent leave of court, formal noticed discovery motions may no longer be
filed and, if filed contrary to this order, will not be heard.
B. Instead, parties (and non-parties involved in a discovery dispute) will first
use the customary convenient means of communication - telephone, e-mail,
correspondence, person to person talks between members of opposing litigation teams -
to try to reach agreement.
C. If that fails to lead to complete agreement, then LEAD COUNSEL (and
any unrepresented person), accompanied by anyone else whose presence is needed to
fully explore resolution, shall meet IN PERSON for as long as and as often as is needed
to reach full agreement.
i. Unjustified delay in arranging the meeting, especially where the
dispute is time sensitive, or refusal to attend or to participate meaningfully will be grounds
for sanctions and/or for entry of an order in favor of the other side. Except in extreme
circumstances, excuses such as press of business, inconvenience, or cost will not suffice.
ii. Hopefully, the parties can agree on a site for the in-person meeting
of lead counsel. The most sensible way would probably be for the party advancing the
dispute to pick the place for the first meeting, the other party pick the site for the second,
and alternating thereafter. If the parties cannot agree, then the court requires lead counsel
meet at a location approximately half way between their offices.
D. If the meeting(s) between lead counsel do not resolve the dispute, then
within 5 business days after conclusion of the session(s) (or, 5 days after reaching impasse
as to a particular issue) the parties shall file on pleading paper a “Discovery Dispute Joint
Report #__” (“Joint Report’). In no event may a Joint Report be filed later than 7 days
after the discovery cut-off date(s), as prescribed in Civil L.R. 87-3. As usual, a chambers
copy should also be submitted. |Page 5 i. The Joint Report’s cover page will contain: the case caption; a one
sentence identification of the issue it covers; the date, place, and length of time of the joint
meeting; the close of discovery and any other date that is relevant; and the attestations of
lead counsel that they complied with this Standing Order.
ii. To avoid needless complexity and unwieldiness, the Joint Report
should deal with only one issue (or, at most, a few inextricably related issues).
ii. The Joint Report, including the cover page, shall not exceed 11
pages. It should describe the dispute and the facts essential to understanding it. Then, in
a format that allows ready comparison, it should give each party’s position (with brief
citation to important authority), and - finally - each party’s final and “most reasonable”
proposal for how the court should decide.
iv. The only exhibit permitted to the Joint Report is an exact copy of
the discovery request(s) in issue and the response(s) (if any) to it (i.e.: requests for
documents, interrogatories, privilege log, non-party subpoena, etc.) If it consists of more
than just a few pages, the exhibit shall be indexed.
v. Asingle lead-counsel-in-person session may produce more than
one Joint Report, but the court would look with disfavor on any attempt to use multiple Joint
Reports to skirt the page limitation.
vi. Unjustified delay or refusal to participate meaningfully in the
preparation of the Joint Report is grounds for imposition of sanctions or entry of an order
sought by the other side.
E. Upon receipt of the Joint Report, the court will decide what further
proceedings, if any, are appropriate. If the issue is clearly presented and ripe for decision,
it may simply issue a ruling. Alternatively, other options include: scheduling a telephone
conference, calling for further briefing, or, rarely, holding a hearing.
F. Any party seeking an award of attorney fees or other expenses in
connection with a discovery dispute shall file a noticed motion pursuant to the Northern
District Local Rules. It would ordinarily be presumptuous to file such a motion before the
court has ruled on the dispute.
G. When the parties have become, or expect to become, engaged in a
succession of discovery disputes or otherwise require the ongoing assistance of a neutral
decision maker, the court recommends they consider appointment of a Special Masier.
IT IS SO ORDERED.
Dated: June 3, 2011
HOWARD R. LLOYD
United States Magistrate JudgePage 6 STANDING ORDER FOR ALL JUDGES
OF THE NORTHERN DISTRICT OF CALIFORNIA
CONTENTS OF JOINT CASE MANAGEMENT STATEMENT
Commencing July 1, 2011, all judges of the Northern District of California will require the
identical information in Joint Case Management Statements filed pursuant to Civil Local Rule
16-9. The parties must include the following information in their statement which, except in
unusually complex cases, should not exceed ten pages:
1.
10,
Jurisdiction and Service: The basis for the court’s subject matter jurisdiction over
plaintiff's claims and defendant's counterclaims, whether any issues exist regarding
personal jurisdiction or venue, whether any parties remain to be served, and, if any
parties remain to be served, a proposed deadline for service.
Facts: A brief chronology of the facts and a statement of the principal factual issues in
dispute.
Legal Issues: A brief statement, without extended legal argument, of the disputed points
of law, including reference to specific statutes and decisions.
Motions: All prior and pending motions, their current status, and any anticipated
motions.
Amendment of Pleadings: The extent to which parties, claims, or defenses are expected
to be added or dismissed and a proposed deadline for amending the pleadings.
Evidence Preservation: Steps taken to preserve evidence relevant to the issue reasonably
evident in this action, including interdiction of any document-destruction program and
any ongoing erasures of e-mails, voice mails, and other electronically recorded material.
Disclosures: Whether there has been full and timely compliance with the initial disclosure
requirements of Fed. R. Civ. P. 26 and a description of the disclosures made.
Discovery: Discovery taken to date, if any, the scope of anticipated discovery, any
proposed limitations or modifications of the discovery rules, and a proposed discovery .
plan pursuant to Fed. R. Civ. P. 26(f).
Class Actions: If a class action, a proposal for how and when the class will be certified.
Related Cases: Any related cases or proceedings pending before another judge of this
court, or before another court or administrative body.Page 7 11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
Relief: All relief sought through complaint or counterclaim, including the amount of any
damages sought and a description of the bases on which damages are calculated. In
addition, any party from whom damages are sought must describe the bases on which it
contends damages should be calculated if liability is established.
Settlement and ADR: Prospects for settlement, ADR efforts to date, and a specific ADR
plan for the case, including compliance with ADR L.R. 3-5 and a description of key
discovery or motions necessary to position the parties to negotiate a resolution.
Consent to Magistrate Judge For All Purposes: Whether all parties will consent to have a
magistrate judge conduct all further proceedings including trial and entry of judgment.
Other References: Whether the case is suitable for reference to binding arbitration, a
special master, or the Judicial Panel on Multidistrict Litigation.
Narrowing of Issues: Issues that can be narrowed by agreement or by motion,
suggestions to expedite the presentation of evidence at trial (e.g, through summaries or
stipulated facts), and any request to bifurcate issues, claims, or defenses.
Expedited Trial Procedure: Whether this is the type of case that can be handled under the
Expedited Trial Procedure of General Order No. 64 Attachment A. If all parties agree,
they shall instead of this Statement, file an executed Agreement for Expedited Trial and a
Joint Expedited Case Management Statement, in accordance with General Order No. 64
Attachments B and D.
Scheduling: Proposed dates for designation of experts, discovery cutoff, hearing of
dispositive motions, pretrial conference and trial.
Trial: Whether the case will be tried to a jury or to the court and the expected length of
the trial.
Disclosure of Non-party Interested Entities or Persons: Whether each party has filed the
“Certification of Interested Entities or Persons” required by Civil Local Rule 3-16. In
addition, each party must restate in the case management statement the contents of its
certification by identifying any persons, firms, partnerships, corporations (including
parent corporations) or other entities known by the party to have either: (i) a financial
interest in the subject matter in controversy or in a party to the proceeding; or (ii) any
other kind of interest that could be substantially affected by the outcome of the
proceeding.
Such other matters as may facilitate the just, speedy and inexpensive disposition of this
matter.
PDF Page 1
PlainSite Cover Page
PDF Page 2
ORIG
UNITED STATES DISTRICT COURT i NAL FILED
NORTHERN DISTRICT OF CALIFORNIA Oy 1 4 20
201)
ogilen
Northorn 2, lutea
THINK COMPUTER CORPORATION, San doe Califor i
No. C 11-05496 HRL
Plaintiff (s),
v. ORDER SETTING INITIAL CASE
MANAGEMENT CONFERENCE
ROBERT VENCHIARUTTI, ET AL, AND ADR DEADLINES
Defendant(s).
IT IS HEREBY ORDERED that this action is assigned to the Honorable Howard R. Lloyd.
When serving the complaint or notice of removal, the plaintiff or removing defendant must serve on all
other parties a copy of this order , the Notice of Assignment of Case to a United States
Magistrate Judge for Trial, and all other documents specified in Civil Local Rule 4-2. Counsel must
comply with the case schedule listed below unless the Court otherwise orders.
IT IS FURTHER ORDERED that this action is assigned to the Alternative Dispute Resolution
(ADR) Multi-Option Program governed by ADR Local Rule 3. Counsel and clients shall familiarize
themselves with that rule and with the material entitled “Dispute Resolution Procedures in the Northern
District of California” on the Court ADR Internet site at www.adr.cand.uscourts.gov. A limited
number of printed copies are available from the Clerk’s Office for parties in cases not subject to the
court’s Electronic Case Filing program (ECF).
IT IS FURTHER ORDERED that plaintiff or removing defendant serve upon all parties
the brochure entitled “Consenting To A Magistrate Judge’s Jurisdiction In The Northern
District Of California,” additional copies of which can be downloaded from the following
Internet site: http://www.cand.uscourts.gov.
CASE SCHEDULE -ADR MULTI-OPTION PROGRAM
Date Event Governing Rule
11/14/2011 Complaint filed
12/20/2011 *Last day to: FRCivP 26(f) & ADR
* meet and confer re: initial disclosures, early L.R.3-5
settlement, ADR process selection, and discovery plan
- file ADR Certification signed by Parties and Counsel _—Civil_L.R. 16-8 (b) &
(form available at http://www.cand.uscourts.gov) ADR LR. 3-5(b)
* file either Stipulation to ADR Process or Notice of Civil L.R. 16-8 (c) &
Need for ADR Phone Conference (form available at ADR L.R. 3-5(b) &
http://www.cand.uscourts.gov) (c)
PDF Page 3
1/3/2012 Last day to file Rule 26(f) Report, complete initial ERCivP 26(a) (1)
disclosures or state objection in Rule 26(f) Report and file Civil L.R. 16-9
Case Management Statement per attached Standing Order
re Contents of Joint Case Management Statement (also
available at http://www.cand.uscourts.gov)
1/10/2012 INITIAL CASE MANAGEMENT CONFERENCE _ Civil L.R. 16-10
(CMC) in Courtroom 2, Sth Floor SJ at 1:30 PM
*If the Initial Case Management Conference is continued, the other deadlines are continued
accordingly.
PDF Page 4
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
MAGISTRATE JUDGE HOWARD R. LLOYD
STANDING ORDER RE: INITIAL CASE MANAGEMENT
‘In cases that are randomly assigned to Judge Lloyd for all purposes, the parties are
requested to file their written consent to the assignment of a U.S. Magistrate Judge
for all purposes, or their written declination of consent, as soon as possible.
The civil motion calendar is heard on Tuesdays at 10:00 a.m. The criminal motion
calendar is heard on Thursdays at 9:30 a.m. Motions may be noticed for hearing
pursuant to Civil L.R. 7. Counsel need not reserve a hearing date in advance for civil
motions, although noticed dates may be reset as the Court’s calendar requires.
HOWEVER, do not notice a motion over a civil discovery dispute. Instead, follow this
court's “Standing Order re: Civil Discovery Disputes.”
Parties with questions regarding scheduling (excluding settlement conferences)
should contact Judge Lloyd’s Administrative Law Clerk at (408) 535-5411.
A Case Management Conference will be held on the date and time specified in the
Order Setting Initial Case Management Conference in Courtroom 2, United States
Courthouse, 280 South First Street, San Jose, California. This conference may be
continued only by Court Order pursuant to Civil L.R. 16-2(e). Parties may not
stipulate to continue a Case Management Conference without Court approval.
Pursuant to Civil L.R. 16-9, no later than seven (7) days before the Case
Management Conference, the parties shall file a Joint Case Management
Statement. For the required format and contents of this filing, follow the “Standing
Order for All Judges of the Northern District of California: Contents of Joint Case
Management Statement.” If preparation of a joint statement would cause undue
hardship, the parties may serve and file separate statements, which shall include a
description of the undue hardship.
Plaintiff or removing Defendant shall serve a copy of this Standing Order on all
parties to this action and on all parties subsequently joined, in accordance with
Fed.R.Civ.P 4 and 5. Following service, Plaintiff shall file a certificate of service, in
accordance with Civil L.R. 5-6.
IT IS SO ORDERED.
Dated:
August 22, 2002
Amended February 26, 2007
Amended June 3, 2011
HOWARD R. LLOYD
United States Magistrate Judge
PDF Page 5
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
MAGISTRATE JUDGE HOWARD R. LLOYD
STANDING ORDER RE: CIVIL DISCOVERY DISPUTES
1. Effect of Delay on Discovery Disputes.
The parties and counsel are cautioned not to allow discovery disagreements to drag
on unresolved until some important looming deadline forces them into action. Because of
the press of its other business, the court may not be able to give the dispute its attention
with the same celerity that some or all of the parties think is necessary.
2. Resolving Discovery Disputes
In order for this court to efficiently and flexibly respond to discovery disputes, and
accounting both for (1) parties’ and counsels’ obligation to diligently strive to resolve such
disputes without court involvement and (2) the limitations on available judicial resources:
effective immediately this court adopts a new procedure for resolving discovery disputes.
A. Absent leave of court, formal noticed discovery motions may no longer be
filed and, if filed contrary to this order, will not be heard.
B. Instead, parties (and non-parties involved in a discovery dispute) will first
use the customary convenient means of communication - telephone, e-mail,
correspondence, person to person talks between members of opposing litigation teams -
to try to reach agreement.
C. If that fails to lead to complete agreement, then LEAD COUNSEL (and
any unrepresented person), accompanied by anyone else whose presence is needed to
fully explore resolution, shall meet IN PERSON for as long as and as often as is needed
to reach full agreement.
i. Unjustified delay in arranging the meeting, especially where the
dispute is time sensitive, or refusal to attend or to participate meaningfully will be grounds
for sanctions and/or for entry of an order in favor of the other side. Except in extreme
circumstances, excuses such as press of business, inconvenience, or cost will not suffice.
ii. Hopefully, the parties can agree on a site for the in-person meeting
of lead counsel. The most sensible way would probably be for the party advancing the
dispute to pick the place for the first meeting, the other party pick the site for the second,
and alternating thereafter. If the parties cannot agree, then the court requires lead counsel
meet at a location approximately half way between their offices.
D. If the meeting(s) between lead counsel do not resolve the dispute, then
within 5 business days after conclusion of the session(s) (or, 5 days after reaching impasse
as to a particular issue) the parties shall file on pleading paper a “Discovery Dispute Joint
Report #__” (“Joint Report’). In no event may a Joint Report be filed later than 7 days
after the discovery cut-off date(s), as prescribed in Civil L.R. 87-3. As usual, a chambers
copy should also be submitted. |
PDF Page 6
i. The Joint Report’s cover page will contain: the case caption; a one
sentence identification of the issue it covers; the date, place, and length of time of the joint
meeting; the close of discovery and any other date that is relevant; and the attestations of
lead counsel that they complied with this Standing Order.
ii. To avoid needless complexity and unwieldiness, the Joint Report
should deal with only one issue (or, at most, a few inextricably related issues).
ii. The Joint Report, including the cover page, shall not exceed 11
pages. It should describe the dispute and the facts essential to understanding it. Then, in
a format that allows ready comparison, it should give each party’s position (with brief
citation to important authority), and - finally - each party’s final and “most reasonable”
proposal for how the court should decide.
iv. The only exhibit permitted to the Joint Report is an exact copy of
the discovery request(s) in issue and the response(s) (if any) to it (i.e.: requests for
documents, interrogatories, privilege log, non-party subpoena, etc.) If it consists of more
than just a few pages, the exhibit shall be indexed.
v. Asingle lead-counsel-in-person session may produce more than
one Joint Report, but the court would look with disfavor on any attempt to use multiple Joint
Reports to skirt the page limitation.
vi. Unjustified delay or refusal to participate meaningfully in the
preparation of the Joint Report is grounds for imposition of sanctions or entry of an order
sought by the other side.
E. Upon receipt of the Joint Report, the court will decide what further
proceedings, if any, are appropriate. If the issue is clearly presented and ripe for decision,
it may simply issue a ruling. Alternatively, other options include: scheduling a telephone
conference, calling for further briefing, or, rarely, holding a hearing.
F. Any party seeking an award of attorney fees or other expenses in
connection with a discovery dispute shall file a noticed motion pursuant to the Northern
District Local Rules. It would ordinarily be presumptuous to file such a motion before the
court has ruled on the dispute.
G. When the parties have become, or expect to become, engaged in a
succession of discovery disputes or otherwise require the ongoing assistance of a neutral
decision maker, the court recommends they consider appointment of a Special Masier.
IT IS SO ORDERED.
Dated: June 3, 2011
HOWARD R. LLOYD
United States Magistrate Judge
PDF Page 7
STANDING ORDER FOR ALL JUDGES
OF THE NORTHERN DISTRICT OF CALIFORNIA
CONTENTS OF JOINT CASE MANAGEMENT STATEMENT
Commencing July 1, 2011, all judges of the Northern District of California will require the
identical information in Joint Case Management Statements filed pursuant to Civil Local Rule
16-9. The parties must include the following information in their statement which, except in
unusually complex cases, should not exceed ten pages:
1.
10,
Jurisdiction and Service: The basis for the court’s subject matter jurisdiction over
plaintiff's claims and defendant's counterclaims, whether any issues exist regarding
personal jurisdiction or venue, whether any parties remain to be served, and, if any
parties remain to be served, a proposed deadline for service.
Facts: A brief chronology of the facts and a statement of the principal factual issues in
dispute.
Legal Issues: A brief statement, without extended legal argument, of the disputed points
of law, including reference to specific statutes and decisions.
Motions: All prior and pending motions, their current status, and any anticipated
motions.
Amendment of Pleadings: The extent to which parties, claims, or defenses are expected
to be added or dismissed and a proposed deadline for amending the pleadings.
Evidence Preservation: Steps taken to preserve evidence relevant to the issue reasonably
evident in this action, including interdiction of any document-destruction program and
any ongoing erasures of e-mails, voice mails, and other electronically recorded material.
Disclosures: Whether there has been full and timely compliance with the initial disclosure
requirements of Fed. R. Civ. P. 26 and a description of the disclosures made.
Discovery: Discovery taken to date, if any, the scope of anticipated discovery, any
proposed limitations or modifications of the discovery rules, and a proposed discovery .
plan pursuant to Fed. R. Civ. P. 26(f).
Class Actions: If a class action, a proposal for how and when the class will be certified.
Related Cases: Any related cases or proceedings pending before another judge of this
court, or before another court or administrative body.
PDF Page 8
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
Relief: All relief sought through complaint or counterclaim, including the amount of any
damages sought and a description of the bases on which damages are calculated. In
addition, any party from whom damages are sought must describe the bases on which it
contends damages should be calculated if liability is established.
Settlement and ADR: Prospects for settlement, ADR efforts to date, and a specific ADR
plan for the case, including compliance with ADR L.R. 3-5 and a description of key
discovery or motions necessary to position the parties to negotiate a resolution.
Consent to Magistrate Judge For All Purposes: Whether all parties will consent to have a
magistrate judge conduct all further proceedings including trial and entry of judgment.
Other References: Whether the case is suitable for reference to binding arbitration, a
special master, or the Judicial Panel on Multidistrict Litigation.
Narrowing of Issues: Issues that can be narrowed by agreement or by motion,
suggestions to expedite the presentation of evidence at trial (e.g, through summaries or
stipulated facts), and any request to bifurcate issues, claims, or defenses.
Expedited Trial Procedure: Whether this is the type of case that can be handled under the
Expedited Trial Procedure of General Order No. 64 Attachment A. If all parties agree,
they shall instead of this Statement, file an executed Agreement for Expedited Trial and a
Joint Expedited Case Management Statement, in accordance with General Order No. 64
Attachments B and D.
Scheduling: Proposed dates for designation of experts, discovery cutoff, hearing of
dispositive motions, pretrial conference and trial.
Trial: Whether the case will be tried to a jury or to the court and the expected length of
the trial.
Disclosure of Non-party Interested Entities or Persons: Whether each party has filed the
“Certification of Interested Entities or Persons” required by Civil Local Rule 3-16. In
addition, each party must restate in the case management statement the contents of its
certification by identifying any persons, firms, partnerships, corporations (including
parent corporations) or other entities known by the party to have either: (i) a financial
interest in the subject matter in controversy or in a party to the proceeding; or (ii) any
other kind of interest that could be substantially affected by the outcome of the
proceeding.
Such other matters as may facilitate the just, speedy and inexpensive disposition of this
matter.
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