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At the Rule 26(f) Case Management Meeting, the parties shall discuss and
develop a Proposed Joint Case Management Plan. This plan shall be filed with the
Clerk of Court not less than ten (10) days before the Scheduling Conference and shall
include individually numbered brief statements indicating:
1. The nature of the case, including the factual and legal bases of plaintiff’s
claims and defendant’s defenses;
2. A list of the elements of proof necessary for each count of the Complaint
and each affirmative defense and, if applicable, each counterclaim/crossclaim. For those
claims in which the burden of proof shifts, each party shall list the elements that party
must prove in order to prevail. The list of elements of proof must contain citations to
relevant legal authority (i.e., U.S. statutory and/or administrative law, U.S. Supreme
Court cases, Ninth Circuit Court of Appeals case law, Arizona state case and statutory
law, and other authority as dictated by the conflict of law rules);
3. The factual and legal issues genuinely in dispute and whether they can be
narrowed by stipulation or motion;
4. The jurisdictional basis of the case, citing specific statutes;
5. Parties, if any, which have not been served as well as parties which have
not filed an answer or appearance. Unless counsel can otherwise show cause, the Joint
Proposed Case Management Plan shall be accompanied by a proposed order dismissing
any party which has not been served or appropriate pleadings seeking default judgment
against any non-appearing party;
6. The names of parties not subject to the Court’s jurisdiction;
7. Whether there are further dispositive or partially dispositive issues to be
decided by pretrial motions and hearings, including evidentiary hearings pursuant to
Agenda For Civil Case Management Meeting Sample
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