N.D.R.Civ.P.
[Federal model]
FORM 25. SCHEDULING STATEMENT
[Caption and Names of Parties]
1. Discovery Plan. The parties jointly propose to the court the following discovery plan: [Use separate paragraphs or subparagraphs as necessary if parties disagree.]
Discovery will be needed on the following subjects: (brief description of subjects on which discovery will be needed)
All discovery commenced in time to be completed by (date). [Discovery on (issue for early discovery) to be completed by (date).]
Maximum of ___ interrogatories by each party to any other party. [Responses due ___ days after service.]
Maximum of ___ requests for admission by each party to any other party. [Responses due ___ days after service.]
Maximum of ___ depositions by plaintiff(s) and ___ by defendant(s).
Each deposition [other than of ______] limited to maximum of ___ hours unless extended by agreement of parties.
Reports from retained experts under Rule 26(b)(4) due:
from plaintiff(s) by (date)
from defendant(s) by (date)
Supplementations under Rule 26(e) due (time(s) or interval(s)).
4. Other Items. [Use separate paragraphs or subparagraphs as necessary if parties disagree.]
The parties request a pretrial conference in (month and year).
Plaintiff(s) should be allowed until (date) to join additional parties and until (date) to amend the pleadings.
Defendant(s) should be allowed until (date) to join additional parties and until (date) to amend the pleadings.
All potentially dispositive motions should be filed by (date).
Settlement [is likely] [is unlikely] [cannot be evaluated prior to (date) ] [may be enhanced by use of the following alternative dispute resolution procedure: [______].
Final lists of witnesses and exhibits should be due
from plaintiff(s) by (date)
from defendant(s) by (date)
Parties should have ___ days after service of final lists of witnesses and exhibits to list objections.
The case should be ready for trial by (date) [and at this time is expected to take approximately (length of time)].
[Other matters.]
[Parties sign and date]