American LegalNet, Inc. www.FormsWorkFlow.com IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR COUNTY Plaintiff v. Defendant )))))) Case No. MOTION FOR AN EXPEDITED CIVIL JURY CASE DESIGNATION 1. The parties move the court for an order designating this case as an expedited civil jury case and exempting or removing it from mandatory arbitration, pursuant to ORS 36.405(2)(a) and (b), and from all court rules requiring mediation, arbitration, and other forms of alternative dispute resolution. 2. Each party agrees: a. To fully comply with any agreements set forth in section 4 of this motion as to the scope, nature, and timing of discovery or, if there are no such agreements, to fully comply with the requirements of UTCR 5.150(4). b. That all discovery will be completed by (which must be no later than 21 days before the trial date). c. That they have consulted with the office of the trial court administrator and have agreed on a trial date of . (The trial date must be no later than 120 days from the date of this request and is based on the understanding that ECJC designation will occur expeditiously.) 3. The parties agree: (Check one) G To conduct discovery in accordance with section 4 of this motion. The terms of section 4 supersede UTCR 5.150(4). G To conduct discovery in accordance with the requirements of UTCR 5.150(4). 4. If the parties agree to the scope, nature, and timing of discovery pursuant to UTCR 5.150(3), those discovery provisions are stated here and supersede UTCR 5.150(4). a. Document discovery Set(s) of Requests for Production per party Serve by (date) Produce by (date) b. Depositions Depositions per party Complete by (date) Page 1 226 Form 5.150.1a 226 MOTION FOR AN EXPEDITED CIVIL JURY CASE DESIGNATION 226 UTCR 5.150 (05-06-10) American LegalNet, Inc. www.FormsWorkFlow.com c. Requests for admissions Sets of Requests for Admission per party Serve by (date) Serve response by (date) d. Exchange names, and if known, the addresses and phone numbers, of witnesses Describe categories of witnesses (e.g., those described in UTCR 5.150(4)(a)(i), percipient, lay, expert, all) Exchange by (date) e. Exchange existing witness statements Describe categories of witnesses (e.g., those described in UTCR 5.150(4)(a)(i), percipient, lay, expert, all) Exchange by (date) f. Insurance agreements and policies discoverable pursuant to ORCP 36 B(2) Produce by (date) g. Other, if any: (describe) Produce by (date) 5. The parties agree that expert testimony will be submitted at trial by (specify all that apply): G Report (specify date for exchange) G An alternative to in-person testimony (describe) G In-person testimony 6. To expedite the trial, the parties further agree as follows (describe stipulations such as those concerning marking and admissibility of exhibits, damages, and other evidentiary issues): DATED this day of , 20. Attorney for Attorney for Attorney for Page 2 226 Form 5.150.1a 226 MOTION FOR AN EXPEDITED CIVIL JURY CASE DESIGNATION 226 UTCR 5.150 (05-06-10)