Legal Trial Scheduling Form

LEGAL TRIAL SCHEDULING FORM

This Trial Scheduling Agreement is entered into by and between Client Name: represented by Counsel Name: , and Opposing Party Name: represented by Counsel Name: , in the matter of Case No.: pending in Court: presided over by Judge: .

RECITALS

WHEREAS, the parties seek an agreed scheduling plan to set dates for trial, pretrial disclosures, motions, and related proceedings to promote efficient administration of this matter and to avoid unnecessary motion practice; and

WHEREAS, counsel for the parties have conferred in good faith regarding available dates, estimated trial length, and necessary pretrial preparation and agree to the scheduling commitments set forth in this instrument; and

WHEREAS, the parties acknowledge that the court retains discretion to adopt, modify or reject any portion of this scheduling agreement consistent with applicable rules and the court's calendar.

NOW, THEREFORE, in consideration of the mutual covenants set forth herein and other good and valuable consideration, the parties agree as follows:

1. TRIAL DATE, LOCATION AND TYPE

1.1 Trial is scheduled to commence on at in Courtroom/Department: . Estimated duration of trial: .

1.2 Trial type (select all applicable): Jury Trial Bench Trial

2. PRETRIAL DEADLINES

2.1 Discovery cutoff (complete fact and expert discovery): . Absent extraordinary cause, no discovery shall be reopened after that date without leave of court.

2.2 Deadline to designate experts and produce reports: Plaintiff(s) to disclose by ; Defendant(s) to disclose by .

2.3 Exchange of exhibit lists and exhibits (joint submission format to be used): exchange by . Exhibits shall be numbered sequentially and provided in electronic or physical format as required by the court.

2.4 Exchange of witness lists (including address and contact for subpoenas where required) by .

3. MOTIONS, HEARINGS AND BRIEFING

3.1 All dispositive motions, Daubert motions, and motions in limine must be filed and served by with oppositions due in accordance with applicable rules. The parties request a hearing on motions (if required) on at .

3.2 The parties shall meet and confer regarding narrowing issues prior to filing any motion and shall identify efforts to narrow disputed issues in the motion's cover memorandum.

4. SETTLEMENT CONFERENCE / MEDIATION

4.1 The parties agree to attend a settlement conference/mediation on at . Required attendees: lead counsel and parties or designated representatives with full settlement authority.

4.2 If mediation is conducted, counsel shall provide a confidential mediation statement to the mediator no later than .

5. CONTINUANCES, AMENDMENTS AND LATE DISCLOSURES

5.1 Any request to continue trial or extend deadlines shall be made by written stipulation signed by counsel for all parties and submitted to the court, or by noticed motion showing good cause. Absent agreement, moving party must demonstrate diligence and why relief is necessary.

5.2 Late disclosures of witnesses or exhibits must be promptly produced upon discovery and may, in the court's discretion, result in exclusion unless the producing party shows substantial justification and that opposing parties are not prejudiced by the delay.

6. MEET AND CONFER; GOOD FAITH COOPERATION

6.1 Counsel shall meet and confer concerning logistical trial matters, exhibit and witness handling, electronic presentation of evidence, and any protective orders at least before trial.

6.2 Counsel certify that they will cooperate to avoid surprise at trial and will promptly bring to the court's attention any unresolved disputes arising from this schedule.

7. SANCTIONS

7.1 Failure to comply with deadlines set forth in this agreement may result in sanctions including but not limited to exclusion of testimony or exhibits, monetary sanctions, or other relief the court deems appropriate.

8. NOTICES

9. MISCELLANEOUS PROVISIONS

9.1 Governing Law: This agreement shall be governed by and construed in accordance with the laws of the State of without regard to conflict of laws principles.

9.2 Entire Agreement: This document embodies the full agreement of the parties with respect to scheduling matters addressed herein and supersedes any prior oral or written scheduling agreements between the parties.

9.3 Severability: If any provision of this agreement is held to be invalid or unenforceable, the remaining provisions shall remain in full force and effect and the invalid provision shall be reformed to the minimum extent necessary to be enforceable.

9.4 Amendments and Waiver: Any amendment to this scheduling agreement shall be in writing and signed by counsel for all parties or as ordered by the court. Waiver of any provision shall not constitute waiver of any other provision.

9.5 Counterparts: This agreement may be executed in counterparts, each of which shall be deemed an original and all of which shall constitute one instrument. Signatures delivered electronically by image or PDF shall be deemed original signatures for all purposes.

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