Early Case Conference Meeting and Reports - NRCP 16.1

16.1 CASE CONFERENCE: include these items in your discussion and the report:

1--In what format discovery should be produced? Instead of paper, agree that
a--All interrogatories and request to admit be submitted in a Word document (so it doesn't have to be retyped to respond)
b--All documents be exchanged electronically in pdf format.

2--How you can effect service eg email with an attachment or fax both of which are way cheaper than delivery by hand or mail.

3 --One of the Discovery Commissioners requires three telephone calls and three letters before a discovery motion. Agree in the report that discovery motions can be filed 3 days after one fax or email and 2 t/p calls don't resolve the dispute.

4--For maximum flexibility in changing the discovery deadlines, agree that counsel can stipulate to increase or decrease all discovery deadlines for up to 60 days. (Authority--nrcp rule 16.1 (b)(2) allows counsel to change the normal discovery plan under 16.1 b and c).

5--Agree on bates stamping all documents produced.

6--Agree that all exhibits will be the same numbers for depositions, motions and trial.