1. Initial disclosure: The parties have exchanged their initial disclosure statements, or will exchange them no later than __________.

2. Expert witness disclosure: The parties shall simultaneously disclose areas of expert testimony by __________. (Alternative: Plaintiff shall disclose areas of expert testimony by __________, and Defendant shall disclose areas of expert testimony by __________.)

The parties shall simultaneously disclose the identity and opinions of experts by __________. (Alternative: Plaintiff shall disclose the identity and opinions of experts by __________, and Defendant shall disclose the identity and opinions of experts by __________.)

The parties shall simultaneously disclose their rebuttal expert opinions by __________.

3. Lay (non-expert) witness disclosure: The parties shall disclose all lay witnesses by __________. (Alternative: The parties shall disclose lay witnesses in the following order, and by the following dates: __________.)

4. Final supplemental disclosure: Each party shall provide final supplemental disclosure by __________. This order does not replace the parties' obligation to seasonably disclose Rule 26.1 information on an on-going basis and as it becomes available.

5. Discovery deadlines: Tier 2 cases are permitted 180 days in which to complete discovery. The time to complete discovery runs from the date of the Early Meeting. The parties will propound all discovery undertaken pursuant to Rules 33 through 36 by __________. The parties will complete the depositions of parties and lay witnesses by __________, and will complete the depositions of expert witnesses by __________. The parties will complete all other discovery by __________. (“Complete discovery” includes conclusion of all depositions and submission of full and final responses to written discovery.)

6. Settlement conference or private mediation: [choose one]:

Referral to ADR for a settlement conference: The clerk or the court will issue a referral to ADR by a separate minute entry.

Private mediation: The parties shall participate in mediation using a private mediator agreed to by the parties. The parties shall complete the mediation by __________.

All attorneys and their clients, all self-represented parties, and any non-attorney representatives who have full and complete authority to settle this case shall personally appear and participate in good faith in this mediation, even if no settlement is expected. However, if a non-attorney representative requests a telephonic appearance and the mediator grants the request prior to the mediation date, a non-attorney representative may appear telephonically.

No settlement conference or mediation: A settlement conference or private mediation is not ordered.

7. Dispositive motions and trial: The parties shall file all dispositive motions by __________. The parties propose a trial date of no later than _____, and anticipate the number of days for trial to be _____ days.

8. Trial setting conference: On __________ [the court will provide this date], the court will conduct a telephonic trial setting conference. Attorneys and self-represented parties shall have their calendars available for the conference.

Plaintiff Defendant will initiate the conference call by arranging for the presence of all other counsel and self-represented parties, and by calling this division at __________ [division's telephone number] at the scheduled time.

9. Firm dates: No stipulation of the parties that alters a filing deadline or a hearing date contained in this scheduling order will be effective without an order of this court approving the stipulation. Dates set forth in this order that govern court filings or hearings are firm dates, and may be modified only with this court's consent and for good cause. This court ordinarily will not consider a lack of preparation as good cause.