Proposed Scheduling Order Template

[Attorney Name or Party Name]
[Law Firm Name, if applicable]
[Address]
[City, State, ZIP Code]
[Phone Number]
[Email Address]
[Bar Number, if applicable]

IN THE [NAME OF COURT]
FOR [COUNTY / DISTRICT / JURISDICTION]

[Plaintiff / Petitioner Name],
Plaintiff / Petitioner,

v.
[Defendant / Respondent Name],
Defendant / Respondent.

Case No.: [Case Number]

1. Title

PROPOSED SCHEDULING ORDER

Pursuant to [Rule 16 / applicable local rule / court order], the parties submit this Proposed Scheduling Order for the Court’s consideration.

Date of Rule 26(f) Conference, if applicable: [Date]

2. General Case Information

Nature of Case: [Brief description]

Counsel or Parties Participating in the Scheduling Proposal:

[Name / Party / Counsel]

This proposed schedule is:

☐ joint and agreed
☐ joint with noted disagreements
☐ submitted as directed by the Court
☐ other: [Describe]

If any deadlines are disputed, describe the dispute here:

[Insert details]

3. Amendment of Pleadings and Joinder

Deadline to move to amend pleadings: [Date]

Deadline to join additional parties: [Date]

If leave of court or stipulation is required, the parties shall proceed under the applicable rules and court orders.

4. Initial Disclosures

Initial disclosures under Rule 26(a)(1) shall be served by:

[Date]

If different timing is requested, state it here:

[Insert details]

5. Discovery Plan and Scope

Fact discovery shall begin on: [Date]

Fact discovery shall be completed by: [Date]

Discovery limits or special provisions, if any:

[Insert limits on depositions, interrogatories, requests for admission, ESI discovery, phased discovery, or other limits]

Additional discovery management terms, if any:

[Insert details]

6. Electronically Stored Information

The parties state the following regarding ESI:

☐ ESI issues are not expected to be significant
☐ ESI preservation has been addressed
☐ the parties request entry of an ESI protocol
☐ the parties request phased ESI discovery
☐ other: [Describe]

Additional ESI terms, if any:

[Insert details]

7. Privilege and Clawback Terms

The parties state the following regarding privilege and work-product issues:

☐ no special provision requested
☐ the parties request a clawback or non-waiver provision
☐ the parties request incorporation of an Evidence Rule 502 agreement
☐ other: [Describe]

Additional privilege procedure terms:

[Insert details]

8. Expert Disclosures

Plaintiff expert disclosures due: [Date]

Defendant expert disclosures due: [Date]

Rebuttal expert disclosures due: [Date]

Expert discovery cutoff: [Date]

Additional expert scheduling terms, if any:

[Insert details]

9. Discovery Motions

Deadline to file discovery motions: [Date]

Before filing a discovery motion, the parties shall:

☐ meet and confer in good faith
☐ request a discovery conference with the Court
☐ submit a joint discovery statement
☐ other: [Describe]

10. Dispositive Motions

Deadline to file dispositive motions: [Date]

Deadline for responses: [Date, if proposed]

Deadline for replies: [Date, if proposed]

Hearing terms, if any:

[Insert details]

11. Alternative Dispute Resolution

The parties propose the following ADR schedule:

☐ no ADR requested at this time
☐ mediation by [Date]
☐ settlement conference by [Date]
☐ private neutral by [Date]
☐ other: [Describe]

Additional ADR notes:

[Insert details]

12. Pretrial Filings

Deadline for motions in limine: [Date]

Deadline for witness lists: [Date]

Deadline for exhibit lists: [Date]

Deadline for deposition designations: [Date]

Deadline for proposed jury instructions or findings of fact and conclusions of law, if applicable: [Date]

Deadline for proposed final pretrial order: [Date]

13. Final Pretrial Conference

Final pretrial conference date: [Date]

Time: [Time]

Location or remote platform: [Location / Platform]

Additional pretrial conference requirements, if any:

[Insert details]

14. Trial Setting

Requested trial term or trial date: [Date]

Trial type:

☐ jury trial
☐ bench trial
☐ other: [Describe]

Estimated trial length: [Number] day(s)

15. Special Case Management Issues

The parties identify the following special case-management issues:

☐ preservation concerns
☐ confidentiality or protective order issues
☐ third-party discovery issues
☐ sequencing of claims or defenses
☐ class certification schedule
☐ bifurcation issues
☐ other: [Describe]

Additional case-management notes:

[Insert details]

16. Modification of Schedule

Any deadline adopted by the Court may be modified only:

☐ by further court order
☐ for good cause shown
☐ by stipulation approved by the Court
☐ as otherwise permitted by rule or standing order

17. Requested Order

The parties respectfully request that the Court enter a Scheduling Order in substantially the form proposed above.

18. Signature Blocks

Dated: [Date]

Plaintiff / Petitioner Counsel Signature: __________________________
Name: [Full Name]
Title: [Attorney for Plaintiff / Self-Represented Party / Other]

Defendant / Respondent Counsel Signature: __________________________
Name: [Full Name]
Title: [Attorney for Defendant / Self-Represented Party / Other]

Additional Signature, if needed: __________________________
Name: [Full Name]
Title: [Title]

19. Court Use Only

IT IS SO ORDERED.

Dated: __________________________

[Judge Name]
[Judge Title]