California Sample Letter for Case Management Plan Order Template [Your Name] [Your Address] [City, State, Zip Code] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Title] [Court Name] [Court Address] [City, State, Zip Code] Re: [Case Number and Title] Dear [Recipient's Name], I am writing this letter to submit a proposed Case Management Plan Order in accordance with the rules and regulations set forth by the State of California. The plan aims to efficiently manage the discovery and litigation process for the aforementioned case. I. Introduction/Background: Provide a brief overview of the case, including the nature of the dispute and the parties involved. Include important dates, such as the filing date and any key events that have taken place during the litigation process. II. Purpose of Case Management Plan Order: Explain the purpose of the Case Management Plan Order, which is to establish a framework for the orderly progression of the case. The plan ensures that all parties involved are aware of case deadlines, discovery schedules, and court appearances. III. Proposed Case Management Plan: Outline the proposed case management plan by specifying various phases of litigation and their corresponding timelines. Each phase should provide specific details regarding the tasks, assignments, and deadlines. Consider the following components: 1. Initial Pleadings: — Deadline to complete the filing of complaints or answers. — Date for mandatory settlement conference, if applicable. 2. Discovery Phase: — Deadline to disclose initial disclosures and exchange discovery requests. — Specific timeline for responses to discovery requests. — Dates for depositions and expert witness disclosures. 3. Motions and Pretrial Proceedings: — Deadline for filing dispositive motions. — Date for pretrial conference and potential settlement discussions. — Specific timelines for filing objections and responses. 4. Trial Preparation and Trial: — Date for meeting and conferring on trial-related issues. — Deadline for completing all trial-related preparations. — Anticipated trial start date. IV. Proposed Alternative Dispute Resolution (ADR) Procedures: — Mention if the parties have agreed to explore any ADR mechanisms, such as mediation or arbitration. — Provide a timeline for ADR proceedings, if applicable. V. Case Management Conference: — Request a case management conference to discuss and finalize the case management plan. — Suggest potential dates and times for the conference. — Offer cooperation in coordinating the conference. VI. Conclusion: Express sincere willingness to collaborate with the court and all parties involved to implement the proposed Case Management Plan Order effectively and efficiently. Thank the recipient for their attention to this matter and express your availability for any further discussions or clarifications. We appreciate your consideration and look forward to your response. Yours sincerely, [Your Name]