Expedited Action
Mediation/Discovery/Pretrial Stipulation
Submit within 21 days of last Answer to avoid a Scheduling Conference.
The parties stipulate that the Court may order the following deadlines to implement the requirements
of Rule 80.11:
1. Last Answer was filed on _________________________.
2. ADR will be scheduled (for a future date) by _________________________ (within 21 days of last
answer) and will be completed by _________________________ (within 90 days of last answer).
3. Initial Disclosures (80.11(e)(2)) due by _________________________ (within 30 days of last answer).
4. Discovery except expert disclosures will be completed by ________________________ (within 180
days).
5. Expert disclosures & reports are due by _________________________ (15 days after discovery
complete).
6. Opposing expert disclosures & reports are due by _________________________ (15 days after any
deposition of other side’s expert).
7. Stipulations to additional discovery (80.11(e)(5)): _________________________.
8. Dispositive motions due by _________________________.
9. Trial ready by _________________________ (270 days from last answer).
10. Estimated length of trial: __________ day(s) or __________ hour(s).
_________________________ ____________________________________
Date Plaintiff/Plaintiff Attorney Signature
_________________________ ____________________________________
Date Defendant/Defendant Attorney Signature
