D(1) Preliminary conference stipulation and order  

APPENDIX D(1)

It is hereby STIPULATED and ORDERED that disclosure shall proceed as follows:

(1) Insurance Coverage (CPLR 3101(f)): If not already provided, shall be furnished by ____ on or before ____.

(2) Bill of Particulars:

(a) Demand for a bill of particulars shall be served by ____ on or before ____.

(b) Bill of particulars shall be served by ____ on or before ____.

(3) Medical Reports and Authorizations:

 

 

 

 

 

 

 

 

(b) A copy of the physician’s report shall be furnished to plaintiff(s) within ____ days of the examination.

(5) Depositions: Choose (a) or (b)

(a)

    

 

 

 

 

(b) The parties shall set a schedule for depositions to be held no later than ____ and shall provide the court with the schedule.

Optional:

□ If one deposition fails to take place as scheduled, the remaining parties’ depositions shall nonetheless proceed as scheduled, except that priorities between defendants and plaintiffs shall be preserved.

(6) Other Disclosure:

(a) All parties, on or before ____, shall exchange names and addresses of all eyewitnesses and notice witnesses, statements of opposing parties and photographs, or, if none, provide an affirmation to that affect.

(b) Authorizations for plaintiff(s)’ employment records for the period ____ shall be furnished on or before ____.

(c) Demand for discovery and inspection shall be served by ____ on or before ____. The items sought shall be produced to the extent not objected to, and objections, if any, shall be stated on or before ____.

(d) Accident reports prepared in the regular course of business shall be exchanged pursuant to CPLR 3101(g) by ____.

 

All such disclosure, unless otherwise noted herein, shall be completed by _______.

(f) Plaintiff shall provide authorizations for the following collateral source providers (CPLR 4545 within __ days:

 

 

 

(7) Impleader; Motion(s) to amend the pleadings, or to add parties: Shall be completed on or before _______.

 

(9) End Date for All Disclosure, other than expert disclosure [must be within 12 months, or 15 months for a complex case]: _______

  

(11) Motions: Any dispositive motion(s) (CPLR 3211 and 3212) shall be made on or before ____.

(12) Note of Issue: _______ shall file a note of issue/certificate of readiness on or before ____. A copy of the stipulation and order, an affirmation stating that the terms of the stipulation and order have been complied with, and an affidavit of service of the affirmation and note of issue shall be served and filed with the note of issue on or before said date.

(13) The parties shall ensure that a stipulation of discontinuance shall be promptly filed if the case settles before the next meeting with the Court. Failure to comply with any of these directions may result in the imposition of costs or sanctions or other action authorized by law.

 

 

Dated:

SO ORDERED:

J. S. C.

In addition to the directives set forth on the annexed pages, it is further ORDERED as follows:

Dated:

SO ORDERED:

J. S. C.