100-00293 - Discovery/Alternate Dispute Resolution Stipulation (02/2017) Page 1 of 1
CIVIL DIVISION
DISCOVERY/ALTERNATE DISPUTE RESOLUTION STIPULATION
The parties to the above entitled cause stipulate that the Court may order the following ADR and Discovery Schedule:
1. All pretrial motions, except those based on the circumstances that arise after the cutoff date or a motion to
dismiss for lack of subject matter jurisdiction shall be filed by __________________________. Motions in Limine
must be filed by the date of Jury Drawing on issues known to counsel at that time.
2. Third parties shall be brought into the action pursuant to V.R.C.P. 14 no later than _______________.
3. All written Discovery shall be sent to the opposite party no later than _______________. Answers thereto shall be
sent no later than _______________.
4. Plaintiff shall disclose experts by _______________. Defendant shall depose those experts, if it chooses to do so
by _______________.
5. Defendant shall disclose experts by _______________. Plaintiff shall depose those experts if it chooses to do so
by _______________.
6. Depositions of all witnesses other than expert witnesses shall be scheduled and taken no later than ___________.
7. All compulsory medical examinations, if required, shall be scheduled and have been conducted by ____________.
8. The parties shall agree to one of the following ADR procedures as set forth in V.R.C.P. Rule 16.3.
☐ Mediation _____________________________ OR ☐ We agree to accept a neutral from list provided by the clerk
Name of Neutrals(s), if agreed)
☐ Binding Arbitration ___________________________ OR ☐ We agree to accept a neutral from list provided by the clerk
Name of Neutrals(s), if agreed)
☐ Neutral Evaluation ___________________________ OR ☐ We agree to accept a neutral from list provided by the clerk
Name of Neutral, if agreed)
☐ Other Method Proposed Agreement and procedure shall be submitted to the Court for approval.
9. Agreement, if any, concerning the payment of the neutral’s fees and expenses shall be submitted with Stipulation.
10. The Alternate Dispute Resolution Session shall be completed by _______________.
Please specify one of the following options:
☐ A. Case Statement, if appropriate, shall be filed with the neutral by _______________.
Necessary Discovery shall be completed by _______________.
☐ B. We agree to accept the assistance of the designated neutral in setting a schedule for completion of the
process
11. Discovery shall be complete and this case ready for trial by _______________.
Estimate Length of Trial: __________ day(s) or __________ hour(s)
Date Attorney for Plaintiff
____________________ ______________________________________
Date Attorney for Plaintiff
____________________ _______________________________________
Date Attorney for Defendant
____________________ _______________________________________
Date Attorney for Defendant
____________________ _______________________________________
