Legal Case Management Plan

LEGAL CASE MANAGEMENT PLAN

This Legal Case Management Plan (the Plan) is entered into on by and between Plaintiff: and Defendant: regarding Case Name: filed in Case No.: (collectively, the Parties).

RECITALS

WHEREAS, the Parties have conferred in good faith and seek to formulate a plan to manage the litigation efficiently, minimize dispute and expense, and expeditiously move the case toward resolution; and

WHEREAS, the Parties intend that this Plan govern the scheduling of pleadings, discovery, expert disclosures, motion practice, and alternative dispute resolution procedures, subject to agreement of the Parties or order of the Court; and

WHEREAS, the Parties agree to cooperate in preserving relevant information, producing responsive discovery, and implementing proportionate, targeted discovery procedures that respect confidentiality and privilege, as set forth below.

NOW, THEREFORE, in consideration of the mutual covenants contained herein, the Parties agree as follows:

1. DEFINITIONS

For purposes of this Plan, the following terms have the meanings set forth below:

(a) "Document" means all written, recorded or graphic material within the scope of Federal Rule of Civil Procedure 34 and any analogous state rule, including electronically stored information ("ESI").

(b) "Confidential Information" means non-public information designated by a producing party pursuant to a protective order that the Court may enter or the Parties may adopt.

2. SCOPE OF THE PLAN

This Plan governs scheduling, discovery procedures, ESI protocols, depositions, motion practice, and alternative dispute resolution in this action, subject to applicable procedural rules and any Court orders. It does not waive any Party's right to seek relief from the Court or modify the Plan by agreement.

3. CASE MANAGEMENT OBJECTIVES

The Parties agree to cooperate to: (a) narrow disputes at issue; (b) limit discovery to relevant, proportional matters; (c) exchange electronic discovery in a reasonably usable format; and (d) attempt to resolve discovery disputes through meet-and-confer procedures before seeking Court intervention.

4. MEET AND CONFER

The Parties will meet and confer telephonically or in person within days of the date of this Plan to discuss discovery, ESI, and any necessary protective order or confidentiality stipulation. Lead counsel shall appear at meet-and-confer sessions and document unresolved issues in a joint letter to the Court where required.

5. CASE SCHEDULE AND MILESTONES

The Parties propose the following schedule, subject to Court approval:

Initial Disclosures due by ; Close of Fact Discovery ; Expert disclosures (plaintiff/expert) by ; Rebuttal expert disclosures by ; Dispositive motions to be filed by ; Pretrial conference scheduled for ; Trial estimated for .

6. DISCOVERY

Discovery shall be conducted in accordance with applicable rules. Absent stipulation or Court order, the Parties agree to the following limits: maximum of interrogatories per party, maximum of requests for production per party, and maximum of depositions per side. Parties may seek leave to exceed these limits for good cause.

7. ELECTRONICALLY STORED INFORMATION (ESI)

The Parties agree to the following ESI protocol framework:

(a) Preservation: Each Party shall take reasonable steps to preserve potentially relevant ESI and shall identify custodians and relevant repositories upon request.

(b) Production Format: ESI shall be produced in a reasonably usable native or searchable image format, accompanied by reasonably necessary metadata. Specific format agreements (e.g., load files, TIFF, native files) shall be documented below:

(c) Search Terms and Sampling: The Parties shall attempt to agree on search terms, sampling procedures, and scope. If disputes arise, the Parties will meet and confer with proposed alternative methods before seeking the Court's resolution.

8. PRIVILEGE AND PROTECTIVE ORDER

The Parties agree to negotiate a proposed protective order protecting Confidential Information and trade secrets, including procedures for clawback and inadvertent production of privileged materials under applicable privilege-clawback rules. Protective order required:

9. MOTION PRACTICE

All motions shall comply with applicable rules and any scheduling order. The Parties agree to a standard briefing schedule of days for opening briefs, and days for responses, absent Court order. Page limits for briefs shall be pages for opening briefs and pages for reply briefs unless otherwise directed.

10. SETTLEMENT AND ADR

The Parties agree to explore settlement and ADR in good faith. The Parties elect: Mediation Early neutral evaluation None at this time

If mediation is selected, target mediation date: ; Proposed mediator (if any):

11. PRESERVATION OF EVIDENCE

Each Party shall preserve potentially relevant documents, ESI, and tangible materials and shall provide reasonable notice if any routinely scheduled destruction or retention policy may affect such materials. A Party's preservation obligations do not extend to non-unique, immaterial information of negligible relevance.

12. PRIVILEGE LOGS AND CLAWBACK

Privilege logs, to the extent required, shall be produced in a commercially reasonable format. The Parties agree that inadvertent production of privileged material shall be addressed under a mutually agreeable clawback provision and shall not constitute a waiver of privilege if handled in accordance with the agreed procedure or Court order.

13. NOTICES

All notices required or permitted under this Plan shall be sent to the addresses provided above by email and by first-class mail or other agreed means. Notice shall be effective upon receipt.

14. AMENDMENTS AND WAIVER

This Plan may be amended by written agreement of the Parties or upon order of the Court. No waiver of any provision of this Plan shall be effective unless in writing and signed by the Party against whom the waiver is asserted.

15. GOVERNING LAW

This Plan shall be governed by and construed in accordance with the laws of the jurisdiction of the Court in which the case is pending, without regard to conflicts of law principles.

16. ENTIRE AGREEMENT; SEVERABILITY

This Plan constitutes the entire agreement between the Parties with respect to the subjects addressed herein and supersedes all prior agreements and understandings, oral or written, related to those subjects. If any provision of this Plan is held unenforceable, the remaining provisions shall continue in full force and effect.

17. COUNTERPARTS

This Plan may be executed in counterparts, each of which shall be deemed an original but all of which together shall constitute one and the same instrument. Signatures transmitted by electronic means shall be effective for all purposes.

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