
2
theories of liability, damages claimed and applicable defenses;
3. The identity and number of any motions to dismiss or other preliminary or pre-
discovery motions which have been filed and the time period in which they shall be filed, briefed
and argued;
4. A discovery plan and schedule including the length of the discovery period, the
anticipated number of fact and expert depositions to be permitted and, as appropriate, the length
and sequence of such depositions;
5. Anticipated areas of any expert testimony, timing for identification of experts,
responses to expert discovery, and exchange of expert reports;
6. An estimate of the volume of documents and computerized information likely to be
the subject of discovery from parties and nonparties and whether there are technological means
which may render document discovery more manageable at an acceptable cost;
7. The advisability of using special master(s) for fact finding, mediation, or discovery
disputes or such other matters as the parties may agree upon;
8. The time period after the close of discovery within which post-discovery dispositive
motions shall be filed, briefed and argued and a tentative schedule for such activities;
9. The possibility of settlement and the timing of Alternative Dispute Resolution,
including the selection of a mediator or arbitrator(s);
10. Whether or not a party or parties desire to use technologically advanced methods of
presentation or court-reporting and, to the extent that this is the case, a determination of the
following:
(a) Fairness issues, including but not necessarily limited to use of such capabilities
by some but not all of the parties and/or by parties whose resources permit or require variations
in the use of such capabilities;