Legal PTC Report

LEGAL PTC REPORT

This Pre-Trial Conference Report is submitted in the matter of Plaintiff: versus Defendant: ; Case Number: ; Court: ; Pre-Trial Conference Date:

RECITALS

WHEREAS, the parties are involved in litigation concerning the claims and defenses set forth in the operative complaint and any answers and counterclaims filed in this action;

WHEREAS, the Court has scheduled a Pre-Trial Conference to address case management, discovery status, trial scheduling, and narrowing of issues for trial; and

WHEREAS, counsel for the parties have conferred and submit this Report to inform the Court and opposing counsel of the current status of the case, outstanding disputes, and proposed scheduling and trial preparations.

NOW THEREFORE, the parties report as follows.

1. CASE STATUS

The current pleadings on file are: . No additional amendments are presently anticipated without leave of court.

2. JURY DEMAND

Jury trial requested: Yes Bench (no jury)

3. DISCOVERY

Discovery completed to date includes written discovery, depositions, and document production as follows:

4. PENDING MOTIONS

List all motions currently pending, their nature, and requested relief:

5. ISSUES TO BE TRIED

The parties identify the following dispositive factual and legal issues to be resolved at trial:

6. WITNESSES AND EXHIBITS

Estimated number of fact witnesses to be called by Plaintiff: ; by Defendant: .

7. SETTLEMENT AND ADR

Have the parties engaged in settlement discussions or ADR sessions? Yes No

8. PROPOSED SCHEDULE AND ESTIMATED TRIAL

Proposed dates for completion of discovery: .

Proposed trial date window: from to .

Estimated length of trial: .

9. RELIEF REQUESTED FROM THE COURT

The parties hereby request the Court consider the following relief or directions at the Pre-Trial Conference:

10. CERTIFICATION

Counsel of record certify that the statements contained in this Report are made in good faith following reasonable inquiry, and that the disclosures and descriptions provided herein are true and accurate to the best of their knowledge. Counsel further certify that they have met and conferred regarding case narrowing and trial preparation in good faith and attempted to resolve discovery disputes without Court intervention where practicable.

11. NOTICES

12. MISCELLANEOUS PROVISIONS

Governing Law. This Report and any disputes concerning scheduling or case management shall be governed by the local rules of the Court and applicable procedural law. The parties submit to the authority of the presiding court for resolution of calendar and pre-trial matters.

Entire Agreement. This Report contains the entire statement of pre-trial positions and agreements reached between the parties for purposes of the Pre-Trial Conference, and supersedes any prior written or oral communications on these matters unless expressly incorporated herein.

Severability. If any provision of this Report is held invalid or unenforceable, such invalidity shall not affect other provisions which can be given effect without the invalid provision; the remaining provisions shall remain in full force and effect.

Amendments and Waiver. Any amendment to the substance of this Report must be made in writing and signed by counsel for both parties and submitted to the Court. The failure to assert any right or remedy shall not operate as a waiver of that right.

Counterparts. This Report may be executed in counterparts, each of which shall be deemed an original, and all of which together shall constitute one instrument. Facsimile or electronic signatures shall be treated as originals for purposes of submission to the Court.

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