CLAIM DEVELOPMENT - MEDIATION TIMELINE
Below is a sample mediation timeline for use after statutory pre litigation schemes have been exhausted:
| Case Activity |
Date |
| Complaint filed |
September 1, 2010 |
| Defendant response due |
October 15, 2010 |
| Case Management Order ("CMO") negotiated and served (3 to 6 months) |
November 15, 2010 |
| Deposit of Non-Privileged, Non Protected Documents |
January 5, 2011 - 35 days after appearance or service of CMO |
| Responses to Insurance Statement and Scope of Work Interrogatories |
January 5, 2011 - 35 days after appearance or service of CMO |
| Plaintiff's Preliminary Defect List and List of Planitiff's Destructive Testing and Inspection Performed to Date |
February 16, 2011 |
| Deadline to Name and Serve parties |
March 18, 2011 |
| Visual Inspection Requests Due to Plaintiff |
March 25, 2011 |
| Plaintiff Publishes Site Inspection Schedule |
March 29, 2011 |
| Initial Visual Inspections |
May 4 through May 7, 2011 |
| Plaintiff's Presentation of Claims |
July 5, 2011 |
| Plaintiff's Invasive Testing |
August 3 through August 7, 2011 |
| Plaintiff's Final Statement of Claims |
September 28, 2011 |
| Plaintiff's Final Cost of Repair Estimate |
October 15, 2011 |
| Plaintiff's Global Settlement Demand to Developer |
October 15, 2011 |
| Initial Plaintiff/Developer Mediation |
Week of October 28, 2011 |
| Developer Defendant's Settlement Demands to Subcontractor Cross-Defendants |
November 6, 2011 |
| Initial Expert Witness Designation |
November 8, 2011 |
| Second Round Mediation (All Parties) |
Week of November 20, 2011 |
| Defense Invasive Testing Requests Due to Plaintiff |
November 27, 2011 |
| Plaintiff Publishes Defense Invasive Testing Schedule |
December 3, 2011 |
| FINAL MEDIATION (ALL PARTIES) |
Week of January 10, 2012 |
| Supplemental Expert Witness Designation |
Per Code |
| Defense Invasive Testing Period |
January 16 through January 20, 2012 |
| Percipient Witness Deposition Schedule Due |
February 23, 2012 |
| Percipient Witness Depositions |
February 30 through February 8, 2012 |
| Expert Witness Deposition Schedule Due |
March 28, 2012 |
| Expert Witness Depositions |
April 4 through May 4, 2012 |
| Pre-Trial Conference |
TBA |
| Recommended Trial Date |
May 15, 2012 |
|
|