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Case5:13-cv-02373-PSG Document3-1 Filed05/24/13 Page1 of 2








Commencing July 1, 2011, all judges of the Northern District of California will require
identical information in Joint Case Management Statements filed pursuant to Civil Local
Rule 16-9. The parties must include the following information in their statement which,
except in unusually complex cases, should not exceed ten pages:




Jurisdiction and Service: The basis for the court’s subject matter jurisdiction over
plaintiff’s claims and defendant’s counterclaims, whether any issues exist regarding
personal jurisdiction or venue, whether any parties remain to be served, and, if any
parties remain to be served, a proposed deadline for service.
Facts: A brief chronology of the facts and a statement of the principal factual issues
in dispute.
Legal Issues: A brief statement, without extended legal argument, of the disputed
points of law, including reference to specific statutes and decisions.

4. Motions: All prior and pending motions, their current status, and any anticipated



5. Amendment of Pleadings: The extent to which parties, claims, or defenses are
expected to be added or dismissed and a proposed deadline for amending the
Evidence Preservation: A brief report certifying that the parties have reviewed the Guidelines
Relating to the Discovery of Electronically Stored Information (“ESI Guidelines”), and confirming
that the parties have met and conferred pursuant to Fed. R. Civ. P. 26(f) regarding reasonable and
proportionate steps taken to preserve evidence relevant to the issues reasonably evident
in this action. See ESI Guidelines 2.01 and 2.02, and Checklist for ESI Meet and Confer.

7. Disclosures: Whether there has been full and timely compliance with the initial

disclosure requirements of Fed. R. Civ. P. 26, and a description of the disclosures

8. Discovery: Discovery taken to date, if any, the scope of anticipated discovery, any

proposed limitations or modifications of the discovery rules, a brief report on whether
the parties have considered entering into a stipulated e-discovery order, a proposed
discovery plan pursuant to Fed. R. Civ. P. 26(f), and any identified discovery disputes.

9. Class Actions: If a class action, a proposal for how and when the class will be


10. Related Cases: Any related cases or proceedings pending before another judge of this

court, or before another court or administrative body.

Effective date: July 1, 2011 (Last Revised November 27, 2012)(cid:3)

Case5:13-cv-02373-PSG Document3-1 Filed05/24/13 Page2 of 2

11. Relief: All relief sought through complaint or counterclaim, including the amount of any

damages sought and a description of the bases on which damages are calculated. In
addition, any party from whom damages are sought must describe the bases on which it
contends damages should be calculated if liability is established.

12. Settlement and ADR: Prospects for settlement, ADR efforts to date, and a specific ADR

plan for the case, including compliance with ADR L.R. 3-5 and a description of key
discovery or motions necessary to position the parties to negotiate a resolution.

13. Consent to Magistrate Judge For All Purposes: Whether all parties will consent to have
a magistrate judge conduct all further proceedings including trial and entry of
judgment. ___ Yes ___ No

14. Other References: Whether the case is suitable for reference to binding arbitration, a

special master, or the Judicial Panel on Multidistrict Litigation.

15. Narrowing of Issues: Issues that can be narrowed by agreement or by motion,

suggestions to expedite the presentation of evidence at trial (e.g., through
summaries or stipulated facts), and any request to bifurcate issues, claims, or

16. Expedited Trial Procedure: Whether this is the type of case that can be handled under

the Expedited Trial Procedure of General Order No. 64 Attachment A. If all parties
agree, they shall instead of this Statement, file an executed Agreement for Expedited
Trial and a Joint Expedited Case Management Statement, in accordance with General
Order No. 64 Attachments B and D.

17. Scheduling: Proposed dates for designation of experts, discovery cutoff, hearing of

dispositive motions, pretrial conference and trial.

18. Trial: Whether the case will be tried to a jury or to the court and the expected

length of the trial.

19. Disclosure of Non-party Interested Entities or Persons: Whether each party has filed
the “Certification of Interested Entities or Persons” required by Civil Local Rule 3-16.
In addition, each party must restate in the case management statement the contents of
its certification by identifying any persons, firms, partnerships, corporations
(including parent corporations) or other entities known by the party to have either: (i)
a financial interest in the subject matter in controversy or in a party to the proceeding;
or (ii) any other kind of interest that could be substantially affected by the outcome of
the proceeding.

20. Such other matters as may facilitate the just, speedy and inexpensive disposition of this


Effective date: July 1, 2011 (Last Revised November 27, 2012)(cid:3)