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1. Case Title |
vs. |
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2. Case No. |
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3. Plaintiffs |
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Name |
Age |
Address |
| (a) |
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| (b) |
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| (c) |
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4. Defendants |
(a) |
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| (b) |
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| (c) |
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5. Nature of Case: |
(State whether P.I., P.D.,wrongful
death, dram shop, etc)
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6. Factual Summary and Theory of Liability or
Defense |
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7. Describe in detail the Complexity of the Case
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8. Suggestion for simplification of the issues.
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9. Describe any amendments that are required to
the pleadings.
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10. Suggestions for obtaining admissions of fact
and documents which will avoid any unnecessary proof. |
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11. Suggested limitations on
discovery. |
Depositions to be taken: (1) Number_____
(2) Duration______________________ |
| Opinion Witnesses: Area(s) of
Expertise__________________________ Number:____ |
Deadlines: Disclosure of Opinion witnesses:
Date-
Completion of written discovery and depositions: Date- |
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12. Is settlement likely and date you will be
ready for settlement conference. |
Date- |
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13. Advisability of alternative dispute
resolution. |
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14. Date on which case should be ready for trial. |
Date- |
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15. Suggested date for next case management conference. |
Date- |
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16. Other matters that may aid in the disposition of the
action. |
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17. Estimated time for trial |
_______days |
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18. Defendant's Insurance carrier. |
Name: |
| Policy limits: |
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Attorney preparing this Memorandum: |
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Client(s) represented: |
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"I certify that I am familiar with the case and
authorized to act on behalf of the client represented" |
______________________________________________
Must be signed by the attorney appearing at the case mgmt
conference |