LitSup_W3_A2

UNITED STATES DISTRICT COURT

DISTRICT OF

---------------------------------------------------------------X

NAME OF PLAINTIFF,

Plaintiff,

-against-

Docket Number:

NAME OF DEFENDANT,

Defendant.

----------------------------------------------------------------X

RULE 26 STIPULATION

Pursuant to Rule 26 of the Federal Rules of Civil Procedure, the undersigned parties hereby stipulate as follows:

1. Within 20 days of the date hereof, the parties shall provide the names, last known addresses, and telephone numbers of individuals likely to have discoverable information relevant to the disputed facts alleged with particularity in the pleadings, identifying the subjects of the information.

GENERAL DEFINITIONS

1. "Correspondence" means any document that either constitutes a communication between two or more persons, or that summarizes the substance of such a communication, whether made directly to the author of the document or otherwise.

2. "Policy" or "Policies" mean any practice, procedure, method, rule, or regulation.

3. The word "agreement" means a contract, agreement, understanding, or arrangement, whether written or oral.

SPECIFIC DEFINITIONS

1. "Complaint" refers to Plaintiffs Summons and Complaint dated ______________, 2005 in the above-captioned action.

2. "Answer" refers to Defendant's Answer dated _______________, 2005 in the above- captioned action.

3. "Counterclaim" refers to Defendant's Counterclaim in the Answer.

INSTRUCTIONS

1. All documents identified in this stipulation should be produced as they are kept in the usual course of business and organized and labeled to correspond to the specific issues identified by the party providing such documents. Please Bates stamp or otherwise number each document produced.

2. All pages now stapled or fastened together should be produced stapled or fastened together, and all documents, which cannot be legibly copied, should be produced in their original form.

   1. This stipulation relates to all documents in the possession of the party providing disclosure or subject to said party’s custody and control, whether directly or indirectly.

3. If any document identified is withheld on the basis of any claim of privilege or otherwise, please provide in writing the following information about each such document:

   1. its date;

   2. the name, position and address of its author;

   3. the name, position and address of each person who received, read or saw the document or copies thereof;

   4. the subject matter and type of document; and

   5. The privilege claimed (e.g., attorney/client privilege, work product doctrine, etc.). For each document withheld under a claim of attorney work product, also state whether the document was prepared in anticipation of litigation or for trial and, if so, identify the anticipated litigation or trial upon which the assertion is based.

4. Each party to this stipulation is under a duty to seasonably supplement the disclosure identified herein should further or additional discoverable information become available to a party.

5. Nothing herein should be construed to broaden or limit the scope of the Federal Rules or the Local Rules.

STIPULATION

1. Within 10 days of the date hereof, the parties shall provide the names, last known addresses, and telephone numbers of individuals likely to have discoverable information relevant to the disputed facts.

2. Within 10 days of the date hereof, the parties shall provide a description, by category and location of all documents, data compilations, and tangible things in the possession, custody, and control of the party that are relevant to disputed facts alleged with particularity in the pleadings.

3. Within _____ days of the date hereof, the parties shall provide copies of those documents, data compilations, and tangible things that were disclosed in accordance with paragraph two hereof.

4. A computation of any category of damages claimed by the disclosing party, making available for inspection and copying as under Rule 34 of the Federal Rules of Civil Procedure the documents or other evidentiary material, not privileged or protected from disclosure, on which such computation is based, including materials bearing on the nature and extent of injuries suffered.

5. Any insurance agreement under which any person carrying on an insurance business may be liable to satisfy part or all of a judgment that may be entered in the action or to indemnify or reimburse for payments made to satisfy the judgment.

6. The identity of any person who may be used at trial to present evidence under Rules 702, 703, or 705 of the Federal Rules of evidence, and the identity of any report prepared by any such person disclosed.

7. Disclosure of any such report identified in response to paragraph six hereof shall be made within _____ days of the trial of this action.

8. Interrogatories shall be served within _______ days of the date hereof, and answers served in accordance with Rule 33 of the Federal Rules of Civil Procedure.

9. Document production requests shall be served on or before ____________, and responses shall be served in accordance with Rule 34 of the Federal Rules of Civil Procedure.

10. Depositions shall commence on or before _______________. Defendant shall produce for deposition the following witnesses: ___________________________________, on the following days. Plaintiff shall produce the following witnesses: __________________________, on the following days: ________________________. Depositions shall take place at the offices of the attorney(s) conducting said deposition.

11 All discovery proceedings shall be completed on or before ______________, unless said date is extended by order of this court.

Dated: ____________________

(Location)

Name of Attorney for Plaintiff____ Name of Attorney for Defendant

By: _______________________ By: _________________________

Attorney (Initials & last 4 SSN) Attorney (Initials & last 4 SSN)