Judge Jennifer E. Willis — United States District Court, Southern District of New York

Consent to Proceed Before US Magistrate Judge

AO 85 (Rev. 02/17) Notice, Consent, and Reference of a Civil Action to a Magistrate Judge UNITED STATES DISTRICT COURT for the __________ District of __________ ) ) ) ) ) Plaintiff v. Civil Action No. Defendant NOTICE, CONSENT, AND REFERENCE OF A CIVIL ACTION TO A MAGISTRATE JUDGE Notice of a magistrate judge’s availability. A United States magistrate judge of this court is available to conduct all proceedings in this civil action (including a jury or nonjury trial) and to order the entry of a final judgment. The judgment may then be appealed directly to the United States court of appeals like any other judgment of this court. A magistrate judge may exercise this authority only if all parties voluntarily consent. You may consent to have your case referred to a magistrate judge, or you may withhold your consent without adverse substantive consequences. The name of any party withholding consent will not be revealed to any judge who may otherwise be involved with your case. Consent to a magistrate judge’s authority. The following parties consent to have a United States magistrate judge conduct all proceedings in this case including trial, the entry of final judgment, and all post-trial proceedings. Printed names of parties and attorneys Signatures of parties or attorneys Dates Reference Order IT IS ORDERED: This case is referred to a United States magistrate judge to conduct all proceedings and order the entry of a final judgment in accordance with 28 U.S.C. § 636(c) and Fed. R. Civ. P. 73. Date: District Judge’s signature Printed name and title Note: Return this form to the clerk of court only if you are consenting to the exercise of jurisdiction by a United States magistrate judge. Do not return this form to a judge. Print Save As... Reset

ESI Plan and Proposed Order

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK Plaintiff(s) -against- Defendant(s) ) ) ) ) ) ) ) ) ) ) ) ) No.: CV___ ESI Plan and [Proposed] Order The parties in this action stipulate and agree that the following ESI Plan and [Proposed] Order shall govern the preservation, collection and production of electronically stored information and documents in this action.
(1) Description of Claims/Counterclaims/CrossClaims: (a) Plaintiff’s Estimated Monetary Damages and Description of Other Relief Sought:

(b) Defendant’s Estimated Damages on any Counterclaim/Cross-Claims and Description of Other Relief Sought:

By signing below, counsel for the parties confirm that they have factored in the potential damages and relief sought in this case, as well as the resources of the parties, to develop an ESI Plan that is proportional to the needs of this case. (2) Meet and Confer. Pursuant to Fed. R. Civ. P. 26(f), counsel are required to meet and confer regarding certain matters relating to electronic discovery before the Initial Pretrial Conference (the Rule 16 Conference). Counsel hereby certify that they have met and conferred to discuss these issues. Date(s) of parties’ meet-and-confer conference(s): (3) Preservation. (a) The parties have discussed the obligation to preserve potentially relevant electronically stored information and agree to the following scope and methods for preservation, including but not limited to: (e.g., retention of electronic data and implementation of a data preservation plan; identification of potentially relevant data; disclosure of the programs and manner in which the data is maintained; identification of computer system(s) utilized; and identification of the individual(s) responsible for data preservation, etc.) Plaintiff(s): Defendant(s):

(b) State the extent to which the parties have disclosed or have agreed to disclose the dates, contents, and/or recipients of “litigation hold” communications. (4) Collection (a) State the extent to which the parties have agreed on the scope of documents to be collected (e.g., custodians and files/folders, servers, databases) for search and review and agreement on methods of collection.

(b) Source(s) of Electronically Stored Information. The parties anticipate that discovery may occur from one or more of the following potential source(s) of electronically stored information [e.g., email, word processing documents, spreadsheets, presentations, databases, instant messages, web sites, blogs, social media, ephemeral data, etc.]: Plaintiff(s):

Defendant(s): (c) Custodians/Databases. The parties have agreed that data will be collected from the following custodians/databases for review: Plaintiff(s): Defendant(s): (5) Search and Review (a) The parties have discussed methodologies or protocols for the search and review of electronically stored information, as well as the disclosure of techniques to be used. (Some of the approaches that may be considered

include: the use and exchange of keyword search lists, “hit reports,” and/or responsiveness rates; concept search; machine learning, or other advanced analytical tools; limitations on the fields or file types to be searched; date restrictions; limitations on whether back-up, archival, legacy, or deleted electronically stored information will be searched; testing; sampling; etc.) To the extent the parties have reached agreement as to search and review methods, provide details below: Plaintiff(s): Defendant(s): (6) Production (a) Limitations on Production. The parties have discussed factors relating to the scope of production, including but not limited to: (i) number of custodians; (ii) date ranges for which potentially relevant data will be drawn; (iii) timing of productions (including phased discovery or rolling productions); (iv) prioritization of review; and (vi) electronically stored information in the custody or control of non-parties. To the extent the parties have reached agreements related to any of these factors, describe below: Plaintiff(s):

Defendant(s): (b) Form(s) of Production and Metadata to be produced: (1) The parties have readied the following agreements regarding the form(s) of productions and metadata fields to be produced: Plaintiff(s): Defendant(s):

(2) Please specify any exceptions to the form(s) of production indicated above (e.g., word processing documents in TIFF with load files, but spreadsheets in native form): (3) Methods to expedite review. The parties have discussed and agree to the following (e.g., de-duplication, email threading, etc.) (4) Privileged Material. (a) Identification. The parties have agreed to the following method(s) for the identification (e.g., form of logs, acceptability of categorical logs for certain categories of communications, production of metadata log in lieu of or in advance of more limited document by document log, categories of documents that need not be logged, disclosure of number of documents withheld pursuant to certain privileges in lieu of document by document log), and the redaction of privileged documents:

(b) Inadvertent Production / Claw-Back Agreements. Pursuant to Fed R. Civ. Proc. 26(b)(5) and F.R.E. 502(e), the parties have agreed to the following concerning the inadvertent production of privileged documents (e.g. “quick-peek” agreements, on-site examinations, non-waiver agreements or orders pursuant to F.R.E. 502(d), etc.) (the parties are referred to the Rule 502 order in Judge Willis's form confidentiality order): (c) The parties have discussed a 502(d) Order. Yes _; No _ The provisions of any such proposed Order shall be set forth in a separate document and presented to the Court for its consideration. (5) Cost of Production. The parties have analyzed their client’s data repositories and have estimated the costs associated with the production of electronically stored information. The factors and components underlying these costs are estimated as follows: (a) Costs. Plaintiff(s):

Defendant(s): (b) Cost Allocation. The parties have considered cost-shifting or cost-sharing and have reached the following agreements, if any: (c) Cost Savings. The parties have considered cost-saving measures, such as the use of a common electronic discovery vendor or a shared document repository, and have reached the following agreements, if any:

The preceding constitutes the agreement(s) reached between the parties to certain matters concerning electronic discovery as of this date. Counsel certify that in connection with preparation of this ESI Plan and [Proposed] Order they are sufficiently knowledgeable in matters relating to their clients’ technological systems to discuss competently issues relating to electronic discovery, or have involved someone competent to address these issues on their behalf. Party:
Party:
Party:
Party:
Party:
By:
By:
By:
By:
By:
Dated: _______, 20 SO ORDERED: Jennifer E. Willis United States Magistrate Judge

Individual Practices in Civil Cases

March 2026 INDIVIDUAL PRACTICES IN CIVIL CASES1 JENNIFER E. WILLIS, UNITED STATES MAGISTRATE JUDGE Courtroom 40 Foley Square, Courtroom 228 Christopher Davis, Courtroom Deputy (212) 805-6710 Chambers United States District Court
Southern District of New York 40 Foley Square, Chambers 425 New York, NY 10007
WillisNYSDChambers@nysd.uscourts.gov Note on Consent Jurisdiction: If the parties wish to consent to having Judge Willis preside over their case for all purposes, the necessary form is available at https://nysd.uscourts.gov/hon- jennifer-e-willis. In consent cases, the Magistrate Judge assumes the role of the District Judge and thus the right to a jury trial is preserved. Any appeal is directly to the Court of Appeals.
I. Communications with Chambers A. Letters. Letters to the Court are permitted. Letters should be filed on ECF2 except for settlement conference submissions and in camera submissions. Letters may not exceed 3 singe-spaced pages in length (exclusive of exhibits). Parties shall not copy the Court on correspondence sent between counsel or the Parties. Pro se Parties. By Standing order, a pro se party must mail all communications with the Court to the Pro Se Intake Unit located at 500 Pearl St., Room 230, New York, NY 10007. A pro se party may not call Chambers or send any document or filing directly to Chambers. Submissions requiring immediate attention should be hand-delivered to the Pro Se Intake Unit. Unless the Court orders otherwise, all communications with the Court will be docketed upon receipt; such docketing shall constitute service on any user of the ECF system. If any other party is not a user of the ECF System (e.g., if there is another pro se party in the case), a pro se party must send copies of any filing to the party and include proof of service affirming that he or she has done so. Questions can be directed to the Pro Se Intake Unit at (212) 805-0175. B. Letter Motions. Letter motions shall be filed on ECF in accordance with the S.D.N.Y. Local Rules. Requests that may be made by letter motion include requests for an adjournment, an extension, a pre-motion conference, sealing, and a settlement conference. Letter motions are limited to 3 single-spaced pages (not including exhibits). Courtesy copies of letter motions are not required unless exhibits, if any, exceed 25 pages. 1 Requests for reasonable accommodations on account of disability or religion with respect to the Court’s rules or in connection with any proceeding before Judge Willis may be emailed to WillisNYSDChambers@nysd.uscourts.gov. Counsel and parties are invited to inform the Court of their preferred pronouns. 2 ECF Rules and Instructions are available at https://www.nysd.uscourts.gov/rules/ecf-related-instructions.

May 2025 C. Requests for Adjournments or Extensions of Time. All requests for adjournments or extensions of time must be filed on ECF as letter motions at least 2 business days before the original deadline. The letter motion must state: (1) the original date(s); (2) the number of previous requests for adjournment or extension; (3) the reason for the extension; and (4) whether the adversary consents and, if not, the reasons given by the adversary for refusing to consent. Emergency requests should be emailed to WillisNYSDChambers@nysd.uscourts.gov and filed on the docket citing the nature of the emergency.

D. Hand Deliveries. Hand-delivered mail should be left with the Court Security Officers at the Worth Street entrance of 500 Pearl Street and may not be brought directly to Chambers.

E. Calendar Matters. For docketing, scheduling and calendar matters, call Chambers at (212) 805-0244 between 9:00 AM and 5:00 PM or email Chambers at WillisNYSDChambers@nysd.uscourts.gov.

II. Motions

A. Pre-Motion Conferences Letters in Civil Cases. In advance of filing a letter with the Court, the Parties are expected to meet and confer regarding a briefing schedule for any anticipated motion. Pre-motion letters seeking a conference should propose a briefing schedule and are required where the proposed motion is returnable before Judge Willis, or where the proposed motion has been referred to Judge Willis, except that no pre- motion letter is required for (i) motions for admission pro hac vice, (ii) motions by litigants in actions where a party is both pro se and incarcerated, (iii) motions for reconsideration or reargument, (iv) motions for a new trial, (v) motions in limine, (vii) motions listed in Fed. R. App. P. 4(a)(4)(A), (viii) motions for recusal, (ix) habeas corpus petitions, (x) applications made by order to show cause, and (xi) Federal Rule of Civil Procedure 12(b)(6) motions to dismiss in lieu of an Answer.

Discovery Motions. Parties shall follow Local Rule 37.2, with the following modifications. Any party wishing to raise a discovery dispute with the Court must first confer in good faith with the opposing party, in person or by telephone, in an effort to resolve the dispute. If the meet-and-confer does not resolve the dispute, a party may submit a letter motion no longer than 3 single-spaced pages, explaining the nature of the dispute and requesting a conference. Such letter motion must state when the meet-and- confer occurred. Any responsive letter should be submitted within 3 business days after submission of the letter motion and should be no longer than 3 single-spaced pages.
Failure to respond within 3 business days will result in a waiver of any objections. The Court will endeavor to resolve the issue without a conference and without the need for formal briefing. However, if formal briefing is required, the Court will either schedule a conference or set a schedule for such briefing.

Motions other than Discovery Motions. To arrange a pre-motion conference for non- discovery matters, the moving party shall submit a letter motion in accordance with Individual Practice I.B. The letter motion should set forth the nature of the anticipated

May 2025 motion. Any responsive letter should be submitted within 3 business days after submission of the letter motion.

Memoranda of Law. The typeface, margins and spacing of motion papers must conform to Local Civil Rule 11.1. Unless prior permission has been granted, memoranda of law in support of and in opposition to motions may not exceed 8,750 words, and reply briefs may not exceed 3,500 words. Memoranda of 10 pages or more shall contain a table of contents and a table of authorities, neither of which shall count against the word limit.
Sur-reply memoranda will not be accepted without prior permission of the Court. All moving papers, letter-motions, and letters filed on ECF or emailed to chambers must be in searchable PDF form. Additionally, to the extent citing unreported cases, parties are requested to use Westlaw citations whenever possible.

B. Summary Judgement Motions. At the meet and confer held before filing the letter seeking leave to move for summary judgment, the Parties should discuss and prepare a joint submission indicating all facts that are not in dispute. If for any reason the Parties are unable to do so, they should submit a separate letter explaining why they should be relieved of that obligation. Moreover, in their own briefs, the Parties should detail the facts that they are relying upon in the facts section of their brief, and should not simply refer to their Local Civil Rule 56.1 submissions or assume the Court has sufficient familiarity with the facts of the case.

C. Oral Argument on Motions. Parties may request oral argument by noting such request on their moving papers or filing a letter requesting the same. Junior members of legal teams representing clients are invited to argue motions they have helped prepare and to question witnesses with whom they have worked. Firms are encouraged to provide this opportunity to junior attorneys for training purposes; a request for oral argument is more likely to be granted if a party identifies a lawyer to argue the motion who has graduated law school within the previous five years.

D. Electronic Device Requests. To the extent Parties or counsel need electronic devices during any proceedings before the Court, the requesting party should complete the form at https://nysd.uscourts.gov/sites/default/files/2020-06/Electronic%20Dev.pdf and return it via email to Chambers, copying opposing counsel. Such electronic device request need not be filed on the docket. Electronic device requests should be submitted by close of business the day before any scheduled appearance.

E. Requests to File Materials Under Seal. All Confidential Materials filed with the Court may be redacted or filed under seal only as the Court directs upon appropriate application by either party or as required by Federal Rule of Civil Procedure 5.2, which describes sensitive information that must be redacted from public court filings.

Any party wishing to file in redacted form any pleading, motion, memorandum, exhibit, or other document, or any portion thereof, based on a party’s designation of information as Confidential, must make a specific request to the Court by letter motion explaining the reasons for seeking to file that submission under seal.

May 2025

The letter motion must be filed in public view, must explain the particular reasons for seeking to file that information under seal, and should not include confidential information sought to be filed under seal. Supporting papers must be filed separately and may be filed under seal or redacted only to the extent necessary to safeguard information to be filed under seal.

The proposed sealed document must be contemporaneously filed under seal in the ECF system and electronically related to the letter motion. The summary docket text, but not the sealed document, will be open to public inspection and should not include confidential information sought to be filed under seal.

The filing party shall also (a) publicly file the document with the proposed redactions, and (b) electronically file under seal a copy of the unredacted document with the proposed redactions highlighted.

Any party unable to comply with the requirement for electronic filing under seal through the ECF system, or who has reason to believe that a particular document should not be electronically filed, must move for leave of the Court to file on paper.

The pendency of the application to seal does not affect any deadlines that may govern the proposed filing. The parties shall comply with such deadlines by filing the redacted version on ECF, serving the unredacted papers at issue on any opposing parties, and providing courtesy copies of the unredacted version to Chambers.

If the Court approves the filing under seal, no further submissions shall be required. If the Court denies, in part, the motion for filing under seal, the party who made the submission shall be required to refile the document with modified redactions as directed by the Court.

F. Motions in Pro Se Cases. As required by Local Civil Rule 7.2, counsel must provide a pro se litigant with printed copies of decisions cited in any submission that are reported exclusively in computerized databases.

Where a party seeks summary judgment against a pro se litigant, the party must also comply with the notice requirements of Local Civil Rule 56.2. Where a party moves to dismiss or for judgment on the pleadings against a pro se litigant and refers to matters outside the pleadings, counsel must serve and file the notice set forth in Local Civil Rule 12.1. In such situations, counsel is strongly encouraged to move in the alternative for summary judgment so that the pro se litigant understands, based on the Local Civil Rule 56.1 submission, exactly what facts are relevant to the motion. Counsel is expected to meet and confer and communicate with a pro se litigant in the same manner as they would other counsel. Pro se litigants are expected to follow the Local Civil Rules, the Federal Rules of Civil Procedure, and the Court’s Individual Practices herein.

May 2025 G. Motions Requiring Submission of an Excel Sheet. When a Party submits any of the following motions to Judge Willis, or within fourteen days of the referral of such a motion to Judge Willis, the moving Party shall submit an Excel sheet including the relevant calculations. An Excel sheet is required even if the motion was already submitted to a District Judge. Excel sheets are required for the following motions: 1) Inquests on Damages 2) Motions for Attorney’s Fees 3) FLSA Damages 4) IDEA Reimbursements. The Excel sheet should be emailed to WillisNYSDChambers@nysd.uscourts.gov and should CC all opposing counsel or the pro se litigant if they are unrepresented. A letter should also be filed on the docket providing the date and time the Excel sheet was emailed.

III. Pre-Trial Practice

A. Initial Case Management Conference. Before the Initial Case Management Conference, parties must meet and confer on a discovery plan. One week before the scheduled conference, the parties shall file on ECF a Proposed Case Management Plan and Report of Rule 26(f) Meeting. Parties shall use the template available at https://nysd.uscourts.gov/hon-jennifer-e-willis.

If any party is pro se, parties shall use the Proposed Case Management Plan for Pro Se Cases template available at https://nysd.uscourts.gov/hon-jennifer-e-willis. The pro se party should submit the Proposed Case Management Plan for Pro Se Cases to the Pro Se Intake Unit and the represented party should submit it via ECF and simultaneously mail a copy to the pro se party.

Lead counsel for the parties are expected to attend the Initial Case Management Conference. Reasonable accommodations will be made for parties or their counsel who cannot attend in person on account of disability. An incarcerated party who is unable to attend this or other conferences will be able to participate by telephone or video.

B. Case Management Conferences. The Court shall hold regular case management conferences. Counsel are expected to be prepared for such conferences and ready to discuss the status of discovery, the potential for settlement, and any other issues. Junior members of legal teams are invited to address the Court at case management conferences.
Firms are encouraged to provide this opportunity to junior attorneys for training purposes.

C. Deposition Disputes. If a dispute arises during a deposition, the Parties should attempt to proceed through as much of the deposition as possible that is unaffected by the dispute.
Parties should not unilaterally terminate a deposition and the Court expects good faith efforts to resolve any disputes. After doing so, if the dispute cannot be resolved, the Parties should jointly contact the Court at (212) 805-0244. Chambers staff will take a message summarizing the dispute and check to see if Judge Willis is available to resolve the issue either through a video conference or a written order.

May 2025 D. Confidentiality Stipulations and Orders. In cases where confidential information will be exchanged, the parties may utilize the Court’s model Protective Order, available at https://nysd.uscourts.gov/hon-jennifer-e-willis. Should the parties apply for a protective order that differs from the Court’s model, the parties should attach the proposed order showing a comparison of how the proposed order differs from the Court’s model.

E. Electronic Discovery. The parties may utilize the model ESI Plan and Proposed Order, as appropriate, available at https://nysd.uscourts.gov/hon-jennifer-e-willis. The model may be modified to the extent appropriate for the case. The Parties should endeavor to agree on an ESI Plan as early as possible in the case.

F. Hearing Transcripts. When applicable, parties shall coordinate the ordering of a hearing transcript from the court reporter. The ordering party shall send a courtesy copy of the transcript to Chambers via email. Pro se parties are exempt from this Rule.

IV. Pretrial Procedures

The following procedures apply only to those cases where the parties have consented under 28 U.S.C. § 636(c) to have all proceedings, including trial, before Judge Willis.

A. Joint Pretrial Orders in Civil Cases. Unless otherwise ordered by the Court, within 30 days from the date of completion of discovery in a civil case, the parties shall submit to the Court for its approval a Joint Pretrial Order. In general, except in pro se cases, a Joint Pretrial Order shall include the following:

a. The full caption of the action; b. The name, address, telephone number and email of each principal member of the trial team; c. A list of each claim and defense that will be tried and identification of the governing law (including applicable regulations) governing each such claim and defense; d. If applicable, a list of any claims and defenses asserted in the pleadings that are not to be tried;
e. A list by each party of its trial witnesses that it, in good faith, expects to present, with an indication of whether the witnesses will testify in person or by deposition and the general subject area of the witness’s testimony and anticipated length of time needed for each witness; f. A statement as to how and when the parties will give notice to each other of the order of their trial witnesses and, if the parties cannot agree, the parties’ statement that they will agree to the Court’s default rule (i.e. that the parties shall advise each other by no later than 48 hours before the start of trial as to the order of their witnesses); g. A list by each party of exhibits that it, in good faith, expects to offer in its case in chief, together with any specific objections thereto; h. All stipulations or statements of fact or law on which the parties have agreed;

May 2025 i. A proposed schedule by which the parties will exchange demonstratives that the parties intend to use at trial, notify each other of any objections thereto, consult with each other regarding those objections, and notify the Court of any remaining disputes; j. Proposed voir dire questions; k. Proposed jury instructions; l. Proposed verdict sheet;
m. The estimated length of trial; and n. All other matters that the Court may have ordered or that the parties believe are important to the efficient conduct of the trial, such as bifurcation or sequencing of issues to be tried, anticipated in limine motions, and any technology needed for trial.

In pro se cases, no Joint Pretrial Order is needed. Instead, within 30 days after the completion of discovery each party shall file its own Pretrial Statement. The pro se party’s Pretrial Statement need take no particular form, but must be concise and contain: (1) a statement of the facts the party hopes to prove at trial; (2) a list of all documents or other physical objects that the party plans to put into evidence at trial; and (3) a list of the names and addresses of all witnesses the party intends to have testify at trial. The Statement must be sworn by the party to be true and accurate based on the facts known by the party. The party must file an original Pretrial Statement with the Pro Se Office and serve a copy on all other parties or their counsel if represented. The original Pretrial Statement must indicate the date a copy was mailed to the other party or that party’s attorney.

B. Courtesy Copies of Trial Exhibits. The parties shall each send a courtesy copy of all exhibits, pre-marked, to WillisNYSDChambers@nysd.uscourts.gov. Exhibits need not be filed electronically on ECF. The parties shall also each submit one hard copy of the pre-marking exhibits in a well-organized three-ring binder, separated by tab dividers.

V. Settlement Conferences

The parties shall refer to the Court’s Standing Order for All Cases Referred for Settlement to Magistrate Judge Jennifer E. Willis, available at https://nysd.uscourts.gov/hon-jennifer-e-willis, for applicable guidelines.

Individual Practices in Criminal Cases

August 2022 INDIVIDUAL PRACTICES IN CRIMINAL CASES JENNIFER E. WILLIS, UNITED STATES MAGISTRATE JUDGE Chambers

Deputy United States District Court

Christopher Davis Southern District of New York 40 Foley Square, Room 425 New York, NY 10007 Phone: (212) 805-0244 Fax: (212) 805-7906 I. Criminal Applications

a. Warrants. Arrest and search warrants, including applications for cell site information, triggerfish, and GPS tracking, should be emailed to WillisCriminalDuty@nysd.uscourts.gov. The cover email should specify the time that the agent and AUSA are available to swear out the complaint or affidavit.

b. PEN Registers, NDOs, and OCs. All applications requiring Judge Willis’s review and signature should be sent to WillisCriminalDuty@nysd.uscourts.gov.

c. Late-night or weekend warrants. If you anticipate the need for a late-night or weekend warrant, please send Judge Willis an email at WillisCriminalDuty@nysd.uscourts.gov, and call Judge Willis on her personal cell phone, available on the criminal duty roster.

II. Pleas. At least 24 hours in advance of a plea, the indictment/information, plea agreement, a summary of the elements of the offense(s), and the maximum and mandatory penalties for each crime/count should be emailed to WillisCriminalDuty@nysd.uscourts.gov.

III. Misdemeanor Sentencing. Pre-sentence submissions for misdemeanors should be submitted no later than 2 weeks before the scheduled sentencing.

Model Protective Order

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK

• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • X XX CIV XXXX (XXX) (XXX) STIPULATION AND PROPOSED PROTECTIVE ORDER Plaintiff(s), XXXXXXXXXX, against XXXXXXXXXX Defendant(s). : : : : : : : : : :
• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • X WHEREAS, the Parties having agreed to the following terms of confidentiality, and the Court having found that good cause exists for the issuance of an appropriately tailored confidentiality order pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, it is hereby ORDERED that the following restrictions and procedures shall apply to the information and documents exchanged by the parties in connection with the pre-trial phase of this action:

Counsel for any party may designate any document or information, in whole or in part, as confidential if counsel determines, in good faith, that such designation is necessary to protect the interests of the client in information that is proprietary, a trade secret or otherwise sensitive non-public information. Information and documents designated by a party as confidential will be stamped "CONFIDENTIAL." 2. The Confidential Information disclosed will be held and used by the person receiving such information solely for use in connection with the action. 3. In the event a party challenges another party's designation of confidentiality, counsel shall make a good faith effort to resolve the dispute, and in the absence of a resolution, the challenging party may seek resolution by the Court. Nothing in this Protective Order constitutes an admission by any party that Confidential Information disclosed in this case is relevant or admissible. Each party reserves the right to object to the use or admissibility of the Confidential Information. 4. The parties should meet and confer if any production requires a designation of "For Attorneys' or Experts' Eyes Only." All other documents designated as

"CONFIDENTIAL" shall not be disclosed to any person, except: a. The requesting party and counsel, including in-house counsel; b. Employees of such counsel assigned to and necessary to assist in the litigation; c. Consultants or experts assisting in the prosecution or defense of the matter, to the extent deemed necessary by counsel; and d. The Court (including the mediator, or other person having access to any Confidential Information by virtue of his or her position with the Court). 5. Prior to disclosing or displaying the Confidential Information to any person, counsel must: a. Inform the person of the confidential nature of the information or documents; b. Inform the person that this Court has enjoined the use of the information or documents by him/her for any purpose other than this litigation and has enjoined the disclosure of the information or documents to any other person; and c. Require each such person to sign an agreement to be bound by this Order in the form attached hereto. 6. The disclosure of a document or information without designating it as "confidential" shall not constitute a waiver of the right to designate such document or information as Confidential Information. If so designated, the document or information shall thenceforth be treated as Confidential Information subject to all the terms of this Stipulation and Order. 7. Any Personally Identifying Information (“PII”) (e.g., social security numbers, financial account numbers, passwords, and information that may be used for identity theft) exchanged in discovery shall be maintained by the receiving party in a manner that is secure and confidential and shared only with authorized individuals in a secure manner. The producing party may specify the minimal level of protection expected in the storage and transfer of its information. In the event the party who received PII experiences a data breach, it shall immediately notify the producing party of same and cooperate with the producing party to address and remedy the breach. Nothing herein shall preclude the producing party from asserting legal claims or constitute a waiver of legal rights and defenses in the event of litigation arising out of the receiving party’s failure to appropriately protect PII from unauthorized disclosure. 8. Pursuant to Federal Rule of Evidence 502, the production of privileged or work- product protected documents or communications, electronically stored

information (“ESI”) or information, whether inadvertent or otherwise, shall not constitute a waiver of the privilege or protection from discovery in this case or in any other federal or state proceeding. This Order shall be interpreted to provide the maximum protection allowed by Federal Rule of Evidence 502(d). Nothing contained herein is intended to or shall serve to limit a party’s right to conduct a review of documents, ESI or information (including metadata) for relevance, responsiveness and/or segregation of privileged and/or protected information before production.
9. Notwithstanding the designation of information as “confidential” in discovery, there is no presumption that such information shall be filed with the Court under seal. The parties shall follow the Court’s procedures with respect to filing under seal. 10. At the conclusion of litigation, Confidential Information and any copies thereof shall be promptly (and in no event later than 30 days after entry of final judgment no longer subject to further appeal) returned to the producing party or certified as destroyed, except that the parties' counsel shall be permitted to retain their working files on the condition that those files will remain protected. 11. Nothing herein shall preclude the parties from disclosing material designated to be Confidential Information if otherwise required by law or pursuant to a valid subpoena. SO STIPULATED AND AGREED.

Dated: Dated: SO ORDERED.

JENNIFER E. WILLIS, U.S.M.J. Dated: New York, New York

Agreement I have been informed by counsel that certain documents or information to be disclosed to me in connection with the matter entitled have been designated as confidential. I have been informed that any such documents or information labeled "CONFIDENTIAL" are confidential by Order of the Court. I hereby agree that I will not disclose any information contained in such documents to any other person. I further agree not to use any such information for any purpose other than this litigation. DATED: Signed in the presence of: (Attorney)

Proposed Case Management Plan for Pro Se Cases

December 2025

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK

Plaintiff, against Defendant. X : : : : : : : : : : : : : X CIVIL ACTION NO.:

PROPOSED CASE MANAGEMENT PLAN FOR PRO SE CASE

1. Summary of Claims, Defenses, and Relevant Issues. Plaintiff/Defendant (circle one)

2. I understand my obligation to and am preserving relevant information. Plaintiff/Defendant (circle one)

3. Proposed Schedule All discovery should be completed by

a. Depositions: Depositions shall be completed by

b. Neither party may take more than
depositions. Absent an agreement between the parties or an order from the Court, non-party depositions shall follow initial party depositions.

c. Initial Requests for Documents must be made by
. d. Responses to Requests for Documents must be made by

. e. Documents from third-parties (such as doctors) will/will not (circle one) be required. If required, the following are the third-parties from whom Documents will be requested.

f. Subpoenas requesting Documents from third-parties must be served by

. Documents obtained from third-parties must be provided to all parties in this matter.

g. Privilege logs to describe the materials withheld on grounds of privilege will be provided by__________________________________ h. There will/will not (circle one) be expert testimony in this case. If expert testimony will be needed, please describe the topic on which the expert(s) is expected to testify

4. Early Settlement or Resolution The parties have/have not (circle one) discussed the possibility of settlement. The parties request a settlement conference by no later than
   . The following information is needed before settlement can be discussed:

5. Other Matters Plaintiff(s)/Defendant(s) (circle one) wish to discuss the following additional matters at the Initial Case Management Conference.

Respectfully submitted this
day of
.

Name

Address

Phone number

Email

Party representing (if applicable)

Report of Rule 26(f) Conference and Proposed Case Management Plan

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK

Plaintiff, against Defendant. X : : : : : : : : : : : : : CIVIL ACTION NO.: X

PROPOSED CASE MANAGEMENT PLAN AND REPORT OF RULE 26(f) MEETING Court Expectations Rule 1 and Rule 26(b)(1). Counsel are expected to have reviewed Rule 1 and Rule 26(b)(1) and considered their obligations thereunder in discussing and preparing a discovery plan. Additional consideration of proportionality. Counsel shall discuss and consider whether phased or iterative discovery will increase efficiency, reduce costs and lead to a faster resolution of the case when preparing a discovery plan. Document Requests. Counsel shall be fully familiar with their obligations under Rules 34 and 26(g) and consider and discuss ways to ensure compliance and minimize disputes regarding overbreadth and specificity of requests and responses. Competence. Counsel shall be sufficiently knowledgeable in matters relating to their clients’ technological systems to discuss competently issues relating to electronic discovery, or have involved someone competent to address these issues on their behalf. Counsel are directed to the Model Stipulation and Proposed Protective Order and Discussion Topics for Rule 26(f) Conference on Judge Willis's Individual Practices Page. Counsel represent by their signature below that they have read and will comply with the above.

Proposed Discovery Plan In accordance with Federal Rule of Civil Procedure 26(f) and Judge Willis's Individual Rules, the parties met on
(at least one week before the Initial Case Management Conference) and are exchanging communications thereafter. At least one week before the Initial Case Management Conference, the parties submit the following report for the Court’s consideration:

Summary of Claims, Defenses, and Relevant Issues Plaintiff:

Defendant:

Basis of Subject Matter Jurisdiction:

Subjects on Which Discovery May Be Needed Plaintiff(s):

Defendant(s):

Informal Disclosures The information required by Rule 26(a)(1) of the Federal Rules of Civil Procedure was disclosed by Plaintiff(s) on
. In addition, on
, Plaintiff(s) produced/will produce an initial set of relevant documents identified in its Initial Disclosures and will continue to supplement its production.

The information required by Rule 26(a)(1) of the Federal Rules of Civil Procedure was disclosed by Defendant(s) on
. In addition, on
, Defendant(s) produced/will produce an initial set of relevant documents identified in its Initial Disclosures and will continue to supplement its production.

Formal Discovery The parties jointly propose to the Court the following discovery plan: All fact discovery must be completed by
. The parties are to conduct discovery in accordance with the Federal Rules of Civil Procedure and the Local Rules of the Southern District of New York. The following interim deadlines may be extended by the parties on consent without application to the Court, provided that the parties meet the deadline for completing fact discovery set forth in 3(a) above.

a. Depositions: Depositions shall be completed by
and limited to no more than
depositions per party. Absent an agreement between the parties or an order from the Court, non-party depositions shall follow initial party depositions. b. Interrogatories: Initial sets of interrogatories shall be served on or before

. All subsequent interrogatories must be served no later than 30 days prior to the discovery deadline. c. Requests for Admission: Requests for admission must be served on or before
. d. Requests for Production: Initial requests for production were/will be exchanged on
and responses shall be due on

. All subsequent requests for production must be served no later than 30 days prior to the discovery deadline. e. Supplementation: Supplementations under Rule 26(e) must be made within a reasonable period of time after discovery of such information. 7. Privilege Logs Identify the timing and method for producing privilege logs.

Anticipated Discovery Disputes Are there any anticipated discovery disputes? Does either party seek limitations on discovery? Describe.

Amendments to Pleadings a. Are there any amendments to pleadings anticipated?

b. Last date to amend the Complaint:

Joinder of Parties a. Are there other necessary parties that need to be joined? Y/N b. Is joinder of other parties anticipated?

c. Last date to join other parties:

Expert Witness Disclosures At this time, the parties do/do not (circle one) anticipate utilizing experts. Expert discovery shall be completed by
. 12. Electronic Discovery and Preservation of Documents and Information a. Have the parties discussed electronic discovery?

b. Is there an electronic discovery protocol in place? If not, when do the parties expect to have one in place?

c. Are there issues the parties would like to address concerning preservation of evidence and/or electronic discovery at the Initial Case Management Conference?

Anticipated Motions

Early Settlement or Resolution The parties have/have not (circle one) discussed the possibility of settlement. The parties request a settlement conference by no later than
.

The following information is needed before settlement can be discussed:

Trial a. The parties anticipate that this case will be ready for trial by

.

b. The parties anticipate that the trial of this case will require

days.

c. The parties request a jury/bench (circle one) trial.

d. The parties consent/do not consent (circle one) to Magistrate Judge jurisdiction at this time. 16. Other Matters

The parties are advised that they may consent to Magistrate Judge jurisdiction at any time during the case pursuant to 28 USC § 636(c). To consent to Magistrate Judge jurisdiction for all purposes or specific dispositive motions, please utilize the consent form on Judge Willis's Individual Practices Webpage.

Respectfully submitted this
day of
, 20 .

ATTORNEYS FOR PLAINTIFF(S): ATTORNEYS FOR DEFENDANT(S):

Standing Order for All Cases Referred for Settlement

Revised December 2025

STANDING ORDER FOR ALL CASES REFERRED FOR SETTLEMENT TO MAGISTRATE JUDGE JENNIFER E. WILLIS

Chambers Courtroom 40 Foley Square, Room 425 40 Foley Square, Room 228 United States Courthouse United States Courthouse New York, NY 10007 New York, NY 10007 Telephone: (212) 805-0244 WillisNYSDChambers@nysd.uscourts.gov

Introduction

The Court believes the Parties should fully explore settlement at the earliest practical opportunity. Early consideration of settlement allows the parties to avoid the substantial cost, expenditure of time, and uncertainty that are typically a part of the litigation process. Even for those cases that cannot be resolved, early consideration of settlement can provide the parties with a better understanding of the factual and legal nature of their dispute and streamline the issues to be litigated.

Consideration of settlement is a serious matter that requires thorough preparation prior to the settlement conference. It also requires the earnest consideration of the other side’s point of view, as the quote above suggests. Set forth below are the procedures the Court will require the parties and counsel to follow and the procedures the Court typically will employ in conducting the conference.

Confidential Nature of Conference. All settlement conferences are “off the record.” All communications relating to settlement are strictly confidential and may not be used for any purpose. They are not to be used in discovery and will not be admissible at trial.

Magistrate Judge’s Role. The magistrate judge functions as a mediator, attempting to help the parties reach a settlement. Efficient use of this process requires that counsel and their clients be (a) prepared for the conference, and (b) candid with the mediator.

Settlement Letters and Acknowledgement Form. The Parties are required to (1) prepare a pre-conference joint letter, (2) complete an acknowledgement form, and (3) jointly prepare a settlement conference form. These items should be sent via email, with all counsel copied, seven days prior to the date of the pre-conference call to WillisNYSDChambers@nysd.uscourcts.gov. If the Parties choose, they may also submit individual ex parte letters with confidential information to the Court. Each item is discussed in more detail below.

(a) Joint Settlement Letter. The joint letter must not exceed three pages and

Revised December 2025

should include, at a minimum, the following: (a) the history of settlement negotiations, if any, including any prior offers or demands; (b) each party’s evaluation of the settlement value of the case and the rationale for it; (c) any case law authority in support of your settlement position; and (d) any other facts that would be helpful to the Court in preparation for the conference.

(b) Ex Parte Settlement Letter. Although not required, the Parties may also submit an ex parte letter with confidential information for the Court. The letter must be less than one page (unless otherwise authorized by the Court) and marked “Confidential Material for Use Only at Settlement Conference.” The letter should be sent to WillisNYSDChambers@nysd.uscourts.gov and should not be sent to the other parties.

(c) Acknowledgement Form. Counsel for each party shall each complete the Acknowledgment Form that appears following this Standing Order.

(d) Courtesy Copies. If the settlement letter and exhibits exceed 10 pages, the parties are required to submit a courtesy copy to the Court no later than one business day after submission of the letter. The courtesy copy should be placed in well-organized three- ring binder(s). Where appropriate, the binder(s) shall be separated by tab dividers preceded by an exhibit list.

(e) Video. If a Party is submitting a video, the clip shall be provided on a thumb drive delivered to Chambers and labeled with a case name and docket number.
Alternatively, the clip may be emailed to Chambers at WillisNYSDChambers@nysd.uscourts.gov.

Demand. If the plaintiff has not already made a settlement demand, such a demand shall be communicated to the opposing Party no later than 10 days prior to the conference. If it has not already done so, the opposing Party shall respond to any demand no later than three days before the preconference telephone call. Even if plaintiff has made a demand as part of a court-ordered or private mediation previously attended by the parties, plaintiff is still required to make (or renew) a demand. The parties should not wait for the settlement conference to commence negotiations of a resolution of their dispute.

Pre-conference Phone Call. The Court will schedule a pre-conference phone call between the Court and Counsel for the Parties approximately a week before the settlement conference. The call is off the record. The Parties themselves should not attend the call. The purpose of the call is to determine whether it is in the Parties’ interests to invest the significant time and effort that a settlement conference requires.

Attendance of Parties Required. The parties—not just the attorneys—must attend the settlement conference in person. A Party’s attendance is essential to the settlement process. It is vital that the Parties hear the other side’s

Revised December 2025

presentation and have the opportunity to speak with the mediator outside the presence of any adversary. The Parties should be prepared for the settlement conference to last all day. There is a cafeteria in the building.

If a Party resides more than 100 miles from the Courthouse and it would be a great hardship for the Party to attend in person, upon written application in advance of the conference in the form of a letter-motion to be filed on ECF, I will sometimes excuse that Party’s presence but I will require that Party to be available by telephone throughout the settlement conference. Each Party must supply its own simultaneous interpreter (who need not have any special certification), if required. The Court does not provide interpreters for settlement conferences.

Corporate Party or Labor Union. When a corporate Party or labor union is a Party, counsel of record must be accompanied by the person with decision- making authority who gives directions to counsel of record (not someone who has received settlement authority from someone else). Where liability insurance is involved, a decision- making representative of each insurance carrier must attend in addition to the insured. This includes each excess carrier unless specifically excused by the Court at least one week before the conference.
Because it is important that the decision-makers with respect to settlement hear their adversaries’ presentations and be available to answer questions from the Court, the person who attends must be the person with responsibility for determining the amount of any ultimate settlement and who has not had limitations placed by another person with respect to his or her authority to settle. That is, corporate parties, labor unions, and insurance companies (or any other Party that is not a natural person) must send to the conference the person ultimately responsible for giving settlement authority, not someone who has received authority from someone else.

Government Agencies. When any government agency is a Party, counsel of record must be accompanied by a knowledgeable representative from the agency (or, if the agency official with knowledge is more than 100 miles from the Courthouse, the official must be available to participate by telephone). In addition, in cases where the Comptroller of the City of New York has authority over settlement, the Assistant Corporation Counsel must make arrangements in advance of the conference for a representative of the Comptroller either to attend the conference or to be available by telephone for the duration of the conference to approve any proposed settlement.

Use of Interpreters. If a party does not speak fluent English, the Party must bring an experienced simultaneous interpreter. A consecutive interpreter is not acceptable and the attorney on the case may not serve as the interpreter. Simultaneous interpreters are readily available in the commercial marketplace at reasonable rates. Counsel should call Chambers if there is any difficulty in securing an interpreter.

Revised December 2025

Consequences of Non-Compliance with Attendance Requirements. If a Party fails to come to the settlement conference with all the required persons (attorney, plus a decision-making employee from the client, plus a decision- making representative from each insurance carrier), that Party may be required to reimburse all the other parties for their time and travel expenses, and may face other sanctions.

Conference Procedures. Unless advised otherwise by the Court, the conference will take place in Courtroom 228 at 40 Foley Square. At the outset of the mediation, each attorney should be prepared to make a brief presentation in the presence of each other and the parties, summarizing not merely a Party’s positions, but the Party’s interests as well. Written remarks read aloud are usually ineffective. Counsel are also reminded not to treat their opening remarks as if they were the equivalent of a jury address. While there is no formula for the most effective presentation, counsel should consider addressing (a) the most important issues of fact and law, (b) the most recent offer or demand communicated to opposing counsel, and (c) any other matters that may help to advance settlement. The merits of the case are obviously relevant to the value of a potential settlement, but settlement conferences are not the place to make legal arguments. Discussion, if any, of legal issues should be offered solely in the context of settlement, not litigation. Counsel should gear their presentation to the opposing Party, not the Court.

After the initial “joint session,” in most mediations, the Court will spend the rest of the time meeting separately with each side. In these private meetings, the parties and their counsel should be prepared to discuss their position on settlement, the reasons for their position, the amount of attorneys’ fees and litigation expenses incurred to date, and an estimate of the remaining cost of litigating the case to judgment, including any appeal.

Adjournments of Settlement Conferences. A Party may make a written application by letter-motion filed on ECF consistent with Rule I.C. of the Court’s Individual Practices to adjourn or advance the date of the settlement conference without providing cause if the application for a change in date is made at least one week prior to the scheduled conference date. Otherwise, counsel should set forth the reasons for seeking the change in date and must make the application by letter-motion as soon as counsel becomes aware of the need of or potential need for the change. In addition, the parties are required to seek a change in the date if (a) an adjournment would permit necessary discovery or exchange of information that would make the conference more fruitful, or (b) a client who would otherwise be permitted to participate by telephone would be available to attend the conference were it held on another date. Requests for an adjournment on the eve of the scheduled settlement conference are strongly disfavored and not likely to be granted. In no circumstances will a telephone request for an adjournment be entertained.

Revised December 2025

To seek a change in date, the Party should first consult with all other counsel as to their and their clients’ (and insurers’ if applicable) availability on at least three dates. The Party must then file forthwith on ECF, as a letter-motion, a request to adjourn the settlement conference to the agreed-upon date and time. The conference date will not be deemed changed until Chambers receives the letter-motion and it is approved by the Court.

Settlement in Advance of Mediation. If all parties advise the Court in writing that the case has settled prior to the scheduled conference, I will ordinarily adjourn the conference sine die. In these circumstances, the parties should file a letter-motion on ECF requesting an adjournment of the settlement conference sine die, and the Court will then issue a text-only order.

No Effect on Other Deadlines. The scheduling of a settlement conference has no effect on any deadlines or other pending obligations in the case.

SO ORDERED.

Dated: New York, New York December 9, 2025 Jennifer E. Willis, U.S.M.J.

Revised December 2025

ACKNOWLEDGMENT FORM

Complete and send this form by email as a PDF attachment to (1) Judge Willis at WillisNYSDChambers@nysd.uscourts.gov and (2) to all other attorneys who will be attending the conference no later than three days before the preconference telephone call. Your signature indicates your compliance with the certifications below.

Case Name:

Docket Number:
CV
(
) (JW)

I acknowledge that my client and I must attend a settlement conference on

, 20
at .......................... m. in Courtroom 228, United States Courthouse, 40 Foley Square, New York, New York.

1. I am attorney for
   [Plaintiff / Defendant].

a. (For corporate or other non-individual clients): The name of my client’s representative who will attend the conference is:
. The representative’s title is:
.

b. If applicable (for insurance carrier): The name of the representative of the insurance carrier who will attend the conference is:

.

2. Check one line below:

a.
The above-named individual will attend in person.

b. The above-named individual will attend by telephone because I certify that (1) such individual lives and works more than 100 miles from the Courthouse (or, if my client is not an individual, the client’s decision-maker lives and works more than 100 miles from the Courthouse), and (2) it would be a great hardship for this individual to attend a settlement conference on this or any other date. This individual understands that he or she must participate by telephone without interruption for the duration of the conference.

3. I certify that the person attending the conference (in person or by telephone) is the person with ultimate responsibility for determining the settlement amount: that is, the person responsible for giving settlement authority, not someone who has received authority from another person. In addition, if there is an insurance carrier with authority over settlement, a representative from such carrier with complete responsibility over settlement will be present in person or by telephone.

4. I certify that the parties have made a settlement demand and counteroffer.

5. I certify that I read both the Court’s Order scheduling this conference as well as the “Standing Order for All Cases Referred for Settlement to Magistrate Judge Willis.”

Dated:

[signature of attorney]

Revised December 2025

SETTLEMENT CONFERENCE FORM

This form should be completed jointly by the Parties and emailed to WillisNYSDChambers@nysd.uscourts.gov no later than three days before the preconference telephone call. The answers to this form will be kept confidential and fall within Rule 408 of the Federal Rules of Evidence. Please cite to the relevant docket entry where appropriate.

1. Has a deadline for fact discovery been set in this case?
   Yes_________ No___________
   If yes, the discovery deadline is/was______________

If so, is discovery closed?

Yes_________ No___________
If yes, the discovery deadline is/was______________

Does either Party intend to seek to reopen discovery?

Yes____________ No____________

2. Is there a deadline for expert discovery?

Yes_________ No___________

If yes, the expert discovery deadline is/was______________

3. Is either Party waiting to receive records (medical records, payroll records, expert reports, etc.) important to its case?

Yes_________ No___________
If yes, what are those records?____________________ Is the Party still prepared to settle even without receipt of those documents?

4. Has a Motion to Dismiss or Motion on the Pleadings Been Filed?

Yes_________ No___________

If yes, did the District Judge rule on the Motion to Dismiss?

Yes_________ No___________

Revised December 2025

If yes, please list the surviving claims below:

5. Has a Motion for Summary Judgment Been Filed?

Yes_________ No___________

If yes, did the District Judge rule on the Motion?

Yes_________ No___________

If yes, what did the District Judge rule?

Granted_________ Denied___________ Granted in part ________________

6. Are attorney’s fees part of the damages calculation? If so, to date, what are the total attorney fees accumulated in the case?

Yes___________ No_____________

If yes, $_______________

7. Is this a fee-shifting case, if so, please identify the relevant statute.

Yes___________ No_____________

If yes, the relevant statute is:_______________

8. What are the estimated attorney fees for each side for the next stages of the litigation?

Plaintiff $________________ Prefer Not to answer________________

Defendant $________________ Prefer Not to answer________________

9. Are there any financial constraints affecting the settlement discussions the Court should be aware of?

Yes_________ No___________
If yes, what are those financial constraints? ___________________

10. What was Plaintiff’s last best offer? When was this offer made?

$________________

Revised December 2025

Date of Offer:_____________

11. What was Defendant’s last best offer? When was this offer made?

$________________

Date of Offer:_____________

12. If this case were to go to trial, do the Parties anticipate it will be a bench trial or a jury trial?

Bench Trial____________

Jury Trial______________

13. Are there any other impediments to settlement that the Court should be aware of?

Yes_________ No___________

If yes, please describe.____________________

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