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Discovery Plan and Scheduling Order

Draft Discovery Plans and Scheduling Orders in Minutes

8 minutes with Para

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Para is an AI colleague for legal teams. Send it this work by email, Teams or Slack, and it hands back the finished document.

8 minutes with Para

What you'll need

  • Case Information
  • Discovery Scope Details

Plans from $20 a month, with usage included.

Workflow

Overview

Preparing joint discovery plans and scheduling orders is time-consuming and detail-intensive, requiring coordination between parties, careful attention to FRCP 26(f) requirements, and precise deadline calculations. Attorneys spend hours drafting ESI protocols, negotiating discovery limitations, and ensuring all required elements are properly addressed while managing competing deadlines.

CaseMark automates the entire discovery planning process, generating comprehensive, court-ready discovery plans and scheduling orders in minutes. Simply input your case details and preferences, and receive a fully structured document with ESI protocols, privilege protections, and calculated deadlines that comply with federal and local rules.

How to hand this to Para

  1. 1. Send Para the files

    Email them, drop them in a Teams or Slack message, or upload them.

  2. 2. Para runs the Discovery Plan and Scheduling Order skill

    It works from your files and checks its citations against the record.

  3. 3. The finished document comes back

    Para returns it where you asked, usually as a DOCX, and offers the next step.

Example request · email, Teams or Slack
Para, run the Discovery Plan and Scheduling Order skill for the Garcia matter. I've attached the Case Information and Discovery Scope Details. Send the finished draft back here as a DOCX.

What you get

  • Caption

  • Introduction

  • Subjects for Discovery

  • ESI Protocols and Agreements

  • Privilege and Work Product Protections

  • Discovery Limitations

  • Phased Discovery Plan (if applicable)

  • Proposed Deadlines and Milestones

  • Signature Blocks

Required documents

  • Case Information

    Court name, case number, party names, and basic case details

    .pdf, .docx, .txt

  • Discovery Scope Details

    Information about subjects requiring discovery and anticipated evidence

    .pdf, .docx, .txt

Supporting documents

  • Prior Discovery Agreements

    Any existing agreements between parties on discovery protocols

    .pdf, .docx

  • Local Court Rules

    Jurisdiction-specific requirements for scheduling orders

    .pdf, .docx

  • ESI Production Specifications

    Technical specifications for electronic discovery formats and metadata

    .pdf, .docx, .xlsx

Why teams use it

Generate FRCP 26(f)-compliant discovery plans in under 10 minutes instead of 3+ hours

Automated deadline calculations ensure accurate timelines for discovery, experts, and motions

Pre-built ESI protocols and clawback provisions reduce negotiation time with opposing counsel

Customizable templates adapt to commercial litigation, employment disputes, and other case types

Consistent formatting and comprehensive coverage reduce court rejections and revision requests

Questions

What information do I need to generate a discovery plan?

You'll need basic case information (court name, case number, parties), a description of discovery subjects, your preferences for ESI protocols and discovery limitations, and proposed deadlines for key litigation milestones. CaseMark guides you through each required field and provides intelligent suggestions based on standard practice.

Does the tool comply with FRCP 26(f) requirements?

Yes, CaseMark's discovery plan generator is built to comply with Federal Rule of Civil Procedure 26(f) and includes all required elements. The tool can also be customized to meet specific local court rules and standing orders in your jurisdiction.

Can I customize ESI protocols and production formats?

Absolutely. CaseMark provides standard ESI protocol templates that you can customize for your case's specific needs, including production formats, metadata requirements, de-duplication, and search term agreements. You can save custom protocols for reuse across similar cases.

How does the tool calculate discovery deadlines?

CaseMark automatically calculates deadlines based on your proposed trial date and standard discovery periods, working backward to set realistic milestones for fact discovery, expert disclosures, dispositive motions, and pretrial conferences. You can adjust any deadline to fit your case strategy or court requirements.

Can I include phased discovery in the plan?

Yes, CaseMark supports phased discovery proposals. You can specify different phases (such as liability discovery before damages, or core issues before peripheral matters) and set separate deadlines for each phase to manage complex litigation more efficiently.

What if opposing counsel wants to modify the discovery plan?

CaseMark-generated plans are fully editable Word documents, making it easy to incorporate changes requested by opposing counsel or the court. You can quickly regenerate modified versions while maintaining consistent formatting and ensuring all required elements remain included.

Does this work for state court litigation?

Yes, while the default template follows federal rules, CaseMark can be customized for state court requirements. You can modify the rule references, adjust deadline structures, and incorporate state-specific discovery procedures to ensure compliance with your jurisdiction's rules.

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