UNITED STATES DISTRICT COURTMIDDLE DISTRICT OF FLORIDAORLANDO DIVISIONPlaintiff,v.Case No. Defendants.CASE MANAGEMENT REPORTThe parties have agreed on the following dates and discovery plan pursuantto Fed.R.Civ.P. 26(f) and Local Rule 3.05(c):DEADLINE OR EVENT AGREED DATEMandatory Initial Disclosures (pursuant to Fed.R.Civ.P.26(a)(1) as amended effective December 1, 2000)[Court recommends 30 days after CMR meeting]Certificate of Interested Persons and CorporateDisclosure Statement [Each party who has not previously filed must fileimmediately] Motions to Add Parties or to Amend Pleadings[Court recommends 1 - 2 months after CMR meeting]Disclosure of Expert Reports Plaintiff: Defendant:[Court recommends 1 - 2 months before discoverydeadline to allow expert depositions] American LegalNet, Inc. www.FormsWorkFlow.com DEADLINE OR EVENT AGREED DATE Discovery Deadline[Court recommends 6 months before trial to allow time fordispositive motions to be filed and decided; all discoverymust be commenced in time to be completed before thisdate]Dispositive Motions, Daubert, and Markman Motions [Court requires 5 months or more before trial termbegins]Meeting In Person to Prepare Joint Final PretrialStatement[14 days before Joint Final Pretrial Statement]Joint Final Pretrial Statement (Including a Single Set of Jointly-Proposed Jury Instructions and VerdictForm (a Word or WordPerfect256 version may be e-mailed to the Chambers mailbox), Voir DireQuestions, Witness Lists, Exhibit Lists withObjections on Approved Form)[Court recommends 3 weeks before Final PretrialConference]All Other Motions Including Motions In Limine [Courtrecommends 3 weeks before Final Pre-trial Conference]Final Pretrial Conference [Court will set a date that isapproximately 3 weeks before trial]Trial Briefs [Court recommends 2 weeks before Trial]Trial Term Begins[Local Rule 3.05 (c)(2)(E) sets goal of trial within 2 yearsof filing complaint in all Track Two cases; trial term mustnot be less than 4 months after dispositive motionsdeadline (unless filing of such motions is waived); districtjudge trial terms typically begin on the 1 business day ofstthe first full week of each month; trials before magistratejudges will be set on a date certain after consultation withthe parties]Estimated Length of Trial [trial days]Jury / Non-Jury American LegalNet, Inc. www.FormsWorkFlow.com DEADLINE OR EVENT AGREED DATE Mediation Deadline: Mediator: Address: Telephone:[Absent arbitration, mediation is mandatory; Courtrecommends either 2 - 3 months after CMR meeting, orjust after discovery deadline]All Parties Consent to Proceed Before Magistrate JudgeYes No Likely to Agree in Future I.Meeting of Parties in PersonLead counsel must meet in person and not by telephone absent an order permitting otherwise. Counsel will meet in the Middle District of Florida, unless counsel agree on a different location. Pursuant to Local Rule 3.05(c)(2)(B) or (c)(3)(A), a meeting was held in person on1 (date) at (time) at (place) and was attended by: NameCounsel for (if applicable)II.Pre-Discovery Initial Disclosures of Core Information A copy of the Local Rules may be viewed at http://www.flmd.uscourts.gov.1 American LegalNet, Inc. www.FormsWorkFlow.com Fed.R.Civ.P. 26(a)(1)(A) - (D) Disclosures Fed.R.Civ.P. 26, as amended effective December 1, 2000, provides that these disclosures aremandatory in Track Two and Track Three cases, except as stipulated by the parties or otherwiseordered by the Court (the amendment to Rule 26 supersedes Middle District of Florida Local Rule3.05, to the extend that Rule 3.05 opts out of the mandatory discovery requirements): The parties have exchanged agree to exchange (check one)information described in Fed.R.Civ.P. 26(a)(1)(A) - (D) onby(check one) (date).Below is a description of information disclosed or scheduled for disclosure, includingelectronically stored information as further described in Section III below.III.Electronic DiscoveryThe parties have discussed issues relating to disclosure or discovery of electronically storedinformation (223ESI224), including Pre-Discovery Initial Disclosures of Core Information in Section IIabove, and agree that (check one): No party anticipates the disclosure or discovery of ESI in this case; One or more of the parties anticipate the disclosure or discovery of ESI in this case.If disclosure or discovery of ESI is sought by any party from another party, then the following issuesshall be discussed:2 See Generally: Rules Advisory Committee Notes to the 2006 Amendments to Rule 262(f) and Rule 16. American LegalNet, Inc. www.FormsWorkFlow.com A. The form or forms in which ESI should be produced.B. Nature and extent of the contemplated ESI disclosure and discovery, includingspecification of the topics for such discovery and the time period for which discovery will be sought.C. Whether the production of metadata is sought for any type of ESI, and if so, what typesof metadata.D. The various sources of ESI within a party222s control that should be searched for ESI, andwhether either party has relevant ESI that it contends is not reasonably accessible under Rule26(b)(2)(B), and if so, the estimated burden or costs of retrieving and reviewing that information.E. The characteristics of the party222s information systems that may contain relevant ESI,including, where appropriate, the identity of individuals with special knowledge of a party222scomputer systems.F. Any issues relating to preservation of discoverable ESI.G. Assertions of privilege or of protection as trial-preparation materials, including whetherthe parties can facilitate discovery by agreeing on procedures and, if appropriate, an Order under theFederal Rules of Evidence Rule 502. If the parties agree that a protective order is needed, they shallattach a copy of the proposed order to the Case Management Report. The parties should attempt to American LegalNet, Inc. www.FormsWorkFlow.com agree on protocols that minimize the risk of waiver. Any protective order shall comply with LocalRule 1.09 and Section IV. F. below on Confidentiality Agreements.H. Whether the discovery of ESI should be conducted in phases, limited, or focused uponparticular issues.Please state if there are any areas of disagreement on these issues and, if so, summarize the parties222position on each: If there are disputed issues specified above, or elsewhere in this report, then (check one): One or more of the parties requests that a preliminary pre-trial conference under Rule16 be scheduled to discuss these issues and explore possible resolutions. Although this will be anon-evidentiary hearing, if technical ESI issues are to be addressed, the parties are encouraged tohave their information technology experts with them at the hearing.If a preliminary pre-trial conference is requested, a motion shall also be filed pursuantto Rule 16(a), Fed. R. Civ. P. All parties agree that a hearing is not needed at this time because they expect to be ableto promptly resolve these disputes without assistance of the Court.IV.Agreed Discovery Plan for Plaintiffs and Defendants American LegalNet, Inc. www.FormsWorkFlow.com A.Certificate of Interested Persons and Corporate Disclosure Statement 227This Court has previously ordered each party, governmental party, intervenor, non-partymovant, and Rule 69 garnishee to file and serve a Certificate of Interested Persons and CorporateDisclosure Statement using a mandatory form. No party may seek discovery from any sourcebefore filing and serving a Certificate of Interested Persons and Corporate Disclosure Statement. A motion, memorandum, response, or other paper 227 including emergency motion 227 issubject to being denied or stricken unless the filing party has previously filed and served itsCertificate of Interested Persons and Corporate Disclosure Statement. Any party who has notalready filed and served the required certificate is required to do so immediately.Every party that has appeared in this action to date has filed and served a Certificate ofInterested Persons and Corporate Disclosure Statement, which remains current: Yes NoAmended Certificate will be filed by (party) on or before (date). American Lega