Initial case management conference

(a) Timing of conference

The court in a complex case should hold an initial case management conference with all parties represented at the earliest practical date.

(b) Subjects for consideration

At the conference, the court should consider the following subjects:

(1) Whether all parties named in the complaint or cross-complaint have been served, have appeared, or have been dismissed;

(2) Whether any additional parties may be added or the pleadings may be amended;

(3) The deadline for the filing of any remaining pleadings and service of any additional parties;

(4) Whether severance, consolidation, or coordination with other actions is desirable;

(5) The schedule for discovery proceedings to avoid duplication and whether discovery should be stayed until all parties have been brought into the case;

(6) The schedule for settlement conferences or alternative dispute resolution;

(7) Whether to appoint liaison or lead counsel;

(8) The date for the filing of any dispositive motions;

(9) The creation of preliminary and updated lists of the persons to be deposed and the subjects to be addressed in each deposition;

(10) The exchange of documents and whether to establish an electronic document depository;

(11) Whether a special master should be appointed and the purposes for such appointment;

(12) Whether to establish a case-based Web site and other means to provide a current master list of addresses and telephone numbers of counsel; and

(13) The schedule for further conferences.

(c) Objects of conference

Principal objects of the initial case management conference are to expose at an early date the essential issues in the litigation and to avoid unnecessary and burdensome discovery procedures in the course of preparing for trial of those issues.

(d) Meet and confer requirement

The court may order counsel to meet privately before the initial case management conference to discuss the items specified in (a) and to prepare a joint statement of matters agreed upon, matters on which the court must rule at the conference, and a description of the major legal and factual issues involved in the litigation.