Pretrial Conference Checklist for FRCP 16 & 24
The pretrial order must limit the time to –
 join other parties,
 amend the pleadings,
 complete discovery, and
 file motions.
At pretrial conference, the court may act on
anything to facilitate “the just, speedy, and
inexpensive disposition of the action” such as
Calendaring
 determining the timing of summary
adjudication under Rule 56
 setting dates for pretrial conferences
 scheduling the filing and exchange of
witness and exhibit lists for trial,
 scheduling the filing and exchange of any
pretrial briefs
 setting date for trial
Narrowing Scope of Issues
 formulating and simplifying the issues
 eliminating frivolous claims or defenses
 amending the pleadings
 obtaining admissions and stipulations about
facts and documents to avoid unnecessary
proof, and ruling in advance on the
admissibility of evidence
Discovery
 modifying the timing of disclosures
under Rules 26(a) and 26(e)(1)
 modifying the extent of discovery
 providing for disclosure, discovery, or
preservation of electronically stored
information
 including agreements the parties may reach
for asserting claims of privilege or of
protection as trial-preparation material after
information is produced, including
agreements reached under FRE 502
 controlling and scheduling discovery,
including orders affecting disclosures and
discovery under Rule 26 and Rules 29
through 37
Motions
 disposing of pending motions
 determining the appropriateness of summary
adjudication under Rule 56
 directing that before moving for an order
relating to discovery, the movant must
request a conference with the court
Trial Management
 referring matters to a magistrate judge or a
master
 ordering a separate trial under Rule 42(b) of
a claim, counterclaim, crossclaim, third-
party claim, or particular issue
 avoiding unnecessary proof and cumulative
evidence
 limiting the use of expert testimony
 limiting the time allowed to present
evidence
 ordering the presentation of evidence early
in the trial on a manageable issue that might,
on the evidence, be the basis for a judgment
as a matter of law under Rule 50(a) or a
judgment on partial findings under Rule
52(c)
Complex and Difficult Cases
 adopting special procedures for managing
potentially difficult or protracted actions
involving complex issues, multiple parties,
difficult legal questions, or unusual proof
problems
ADR
 using special procedures to assist in
resolving the dispute