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Apply[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]
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]
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]
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.
Initial disclosures under Rule 26(a)(1) shall be served by:
[Date]
If different timing is requested, state it here:
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:
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:
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:
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:
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]
Deadline to file dispositive motions: [Date]
Deadline for responses: [Date, if proposed]
Deadline for replies: [Date, if proposed]
Hearing terms, if any:
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:
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]
Final pretrial conference date: [Date]
Time: [Time]
Location or remote platform: [Location / Platform]
Additional pretrial conference requirements, if any:
Requested trial term or trial date: [Date]
Trial type:
☐ jury trial
☐ bench trial
☐ other: [Describe]
Estimated trial length: [Number] day(s)
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:
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
The parties respectfully request that the Court enter a Scheduling Order in substantially the form proposed above.
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]
IT IS SO ORDERED.
Dated: __________________________
[Judge Name]
[Judge Title]
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For quick answers, scroll below to see the FAQ.
Frequently asked
A proposed scheduling order is a draft case-management order submitted to the court, usually by the parties, suggesting deadlines and procedures for how the case should move forward. In federal civil practice, the actual scheduling order is governed by Rule 16, and some courts also require the parties to submit a joint proposed schedule after the Rule 26(f) conference.
You need a proposed scheduling order to organize the case early and clearly state the deadlines the parties are asking the court to adopt. Rule 16 requires the scheduling order to limit the time to join parties, amend pleadings, complete discovery, and file motions, and it may also modify disclosure timing, discovery scope, ESI handling, privilege procedures, and trial-related dates.
Use a proposed scheduling order when the court’s rules, standing order, or judge’s practice requires the parties to submit one, usually after the Rule 26(f) conference. The exact timing varies by court. For example, one federal district requires filing the proposed scheduling order within 14 days after the Rule 26(f) conference, while Rule 26 ties initial disclosures to that conference unless the court sets a different time.
Start with the court caption, case number, and the date of the Rule 26(f) conference. Then propose clear deadlines for amendment of pleadings, joinder, initial disclosures if needed, fact discovery, expert disclosures, discovery motions, dispositive motions, pretrial submissions, and trial-related settings. Rule 16 also permits including ESI preservation, privilege-clawback procedures, and pre-motion conference requirements, so those can be added where appropriate.
AI Lawyer can help by organizing the proposed order into clear sections so each reviewer can find the requested deadlines and case-management terms quickly. It can also add internal reference fields, scheduling notes, and placeholders that make revisions easier to track. A consistent structure helps reduce repeated edits and lowers the chance of missing key details like expert deadlines, discovery cutoff dates, or trial estimates before the proposal is filed.
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