UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA JACKSONVILLE DIVISION Plaintiff(s), v. Case No. Defendant(s). ______________________________________ CASE MANAGEMENT REPORT The parties have agreed on the following dates and discovery plan pursuant to Fed.R.Civ.P. 26(f) and Local Rule 3.05(c): DEADLINE OR EVENT Mandatory Initial Disclosures (pursuant to Fed.R.Civ.P. 26(a)(1)) [Court recommends 30 days after CMR meeting] AGREED DATE Certificate of Interested Disclosure Statement Persons and Corporate [all parties are directed to complete and file the attached] Motions to Add Parties or to Amend Pleadings Disclosure of Expert Reports Plaintiff: Defendant: Discovery Deadline [Court recommends 5 months before trial to allow time for dispositive motions to be filed and decided; all discovery must be commenced in time to be completed before this date] Dispositive and Daubert Motions [Court requires 4 months or more before trial term begins] American LegalNet, Inc. www.FormsWorkFlow.com DEADLINE OR EVENT Trial Term Begins [Local Rule 3.05 (c)(2)(E) sets goal of trial within 1 year of filing complaint in most Track Two cases, and within 2 years in all Track Two cases; trial term must not be less than 4 months after dispositive motions deadline (unless filing of such motions is waived). Trials before the District Judge will generally be set on a rolling trial term toward the beginning of each month, with a Final Pretrial Conference to be set by the Court the preceding month. If the parties consent to trial before the Magistrate Judge, they will be set for a date certain after consultation with the parties] AGREED DATE (month, year) Estimated Length of Trial [trial days] Jury / Non-Jury Mediation Deadline: Mediator: Address: Telephone: [Mediation is mandatory in most Track Two cases; Court recommends either 2 - 3 months after CMR meeting, or just after discovery deadline; if the parties do not so designate, the Court will designate the mediator and the deadline for mediation. A list of certified mediators is available on the Court's website and from the Clerk's Office.] All Parties Consent to Proceed Before Magistrate Judge If yes, the parties shall complete and all counsel and/or unrepresented parties shall execute the attached Form AO-85. Yes____ No____ I. Meeting of Parties Lead counsel shall meet in person or, upon agreement of all parties, by telephone. (If all parties agree to conduct the case management conference by telephone, they may do so without filing a motion with the Court.) Pursuant to Local Rule 3.05(c)(2)(B) or (c)(3)(A), a meeting was held on ___________________ (date) at was attended by: (time) and American LegalNet, Inc. www.FormsWorkFlow.com Name _______________________________________ _______________________________________ _______________________________________ Counsel for (if applicable) _________________________________ _________________________________ _________________________________ II. Preliminary Pretrial Conference Local Rule 3.05(c)(3)(B) provides that preliminary pretrial conferences are mandatory in Track Three cases. Track Two cases: Parties (check one) [__] request [__] do not request a preliminary pretrial conference before entry of a Case Management and Scheduling Order in this Track Two case. Unresolved issues to be addressed at such a conference include: ____________________________________________________________________ ____________________________________________________________________ ____________________________________________________________________ III. Pre-Discovery Initial Disclosures of Core Information Fed.R.Civ.P. 26(a)(1)(A) - (D) Disclosures The parties (check one) [__] have exchanged [__] agree to exchange information (date). described in Fed.R.Civ.P. 26(a)(1)(A) - (D) on or by IV. Agreed Discovery Plan for Plaintiffs and Defendants A. Certificate of Interested Persons and Corporate Disclosure Statement This Court makes an active effort to screen every case in order to identify parties and interested corporations in which the assigned judge may be a shareholder, as well as for other matters that might require consideration of recusal. Therefore, each party, governmental party, intervenor, non-party movant, and Rule 69 garnishee shall file and serve within fourteen (14) days from that party's first appearance a Certificate of American LegalNet, Inc. www.FormsWorkFlow.com Interested Persons and Corporate Disclosure Statement using the attached mandatory form. No party may seek discovery from any source before filing and serving a Certificate of Interested Persons and Corporate Disclosure Statement. All papers, including emergency motions, are subject to being denied or stricken unless the filing party has previously filed and served its Certificate of Interested Persons and Corporate Disclosure Statement. Any party who has not already filed and served the required certificate is required to do so immediately. Each party has a continuing obligation to file and serve an amended Certificate of Interested Persons and Corporate Disclosure Statement within eleven days of 1) discovering any ground for amendment, including notice of case reassignment to a different judicial officer; or 2) discovering any ground for recusal or disqualification of a judicial officer. A party should not routinely list an assigned district judge or magistrate judge as an "interested person" absent some non-judicial interest. B. Discovery Plan/Deadline The parties shall not file discovery materials with the Clerk except as provided in Local Rule 3.03. Parties should exchange discovery in the most efficient way, which usually means electronically. In propounding and responding to discovery, the parties are directed to consult and comply with the Federal Rules of Civil Procedure, the Local Rules of the United States District Court for the Middle District of Florida, and the Middle District of Florida's Discovery Handbook, available on the Court's website: www.flmd.uscourts.gov/forms/Civil/2015-Civil_Procedure_Handbook.pdf. Each party shall timely serve discovery requests so that the rules allow for a response prior to the discovery deadline. The Court may deny as untimely all motions to compel filed after the discovery deadline or those that fail to comply with the meet and confer requirements contained in American LegalNet, Inc. www.FormsWorkFlow.com Local Rule 3.01(g). The Court notes that the words "confer" and "good faith" contemplate the parties w