Case Management Statement Example: Filing, Service, and Deadlines

A case management statement is a document you file before a scheduled court conference that tells the judge where the lawsuit stands and how the parties propose to move it toward resolution. In federal court, the obligation traces to Rule 16 of the Federal Rules of Civil Procedure, which requires pretrial conferences to manage discovery, narrow the issues, and set firm deadlines.¹ State courts run their own versions of the same process. The formats differ; the purpose does not. Both sides organize the case early so the court can build a realistic schedule.

What Goes In One

The exact template depends on your court. Many jurisdictions use mandatory fill-in-the-blank forms. The substance, though, is remarkably consistent across federal and state courts, and it breaks down into a handful of categories.

Parties and Service

The statement starts with the names and roles of every party, whether each is an individual or a business entity, and whether those names match the caption on the complaint. You also confirm that every defendant has been properly served. If someone has not been served, explain why and give a realistic date for completing service. Courts watch this closely, because a case cannot be managed when a party does not yet know it exists.

Jurisdiction and Venue

You have to confirm the court’s authority over the case. In federal court, that means saying whether jurisdiction rests on a federal legal question or on diversity of citizenship (parties from different states with more than $75,000 at stake). Venue, meaning whether the lawsuit was filed in the right geographic district, gets addressed too. Flag any planned challenge to either. Identify any related cases pending in the same court or elsewhere so the judge can consider coordinating them.

Discovery Plan and Electronic Evidence

This is where most of the strategic work happens. Your proposed discovery plan lays out the subjects where you need to gather evidence, a proposed timeline for completing discovery, and whether discovery should proceed in phases or focus on particular issues first.² The court uses this information to set the discovery cutoff in its scheduling order, so underestimating what you need here will box you in later.

Electronically stored information deserves its own attention. The plan must address how electronic documents will be preserved, searched, and produced, including the file formats the parties will use. If the parties agree on a procedure for handling accidentally produced privileged documents, they can ask the court to memorialize that agreement in a protective order.²

Alternative Dispute Resolution

Courts want to know whether the parties have explored resolving the case without a trial. The statement usually asks whether you have considered or participated in mediation, arbitration, early neutral evaluation, or a settlement conference. Include the date if a session is already scheduled. If you believe the case is unsuitable for any form of alternative resolution, be ready to explain why. Judges are generally skeptical of that position early in a case. Many federal districts require attorneys to certify that they have discussed the available options with their client before the conference.³

Trial Estimate and Jury Demand

You estimate how long trial will take, stated in days. This number matters more than it may seem. Courts build calendars around it, and an inflated or deflated estimate draws scrutiny. A straightforward contract dispute with two witnesses is not a ten-day trial. Be realistic.

The statement also asks whether any party demands a jury trial or waives that right. That answer affects scheduling, procedural requirements going forward, and the fees you will owe. Jury fees vary by jurisdiction and are typically required as a deposit when the demand is made.

The Meet-and-Confer That Has to Happen First

You cannot draft an accurate statement in federal court without first talking to the other side. Rule 26(f) requires the parties to confer as soon as practicable, and no later than 21 days before the scheduling conference or the deadline for the court’s scheduling order.² This is not optional. The attorneys, or unrepresented parties, are jointly responsible for arranging the meeting and attempting in good faith to agree on a discovery plan.

During the conference, both sides discuss the nature of the claims and defenses, explore whether early settlement is realistic, address how to preserve electronic evidence, and develop the proposed discovery plan. Within 14 days after the conference, the parties submit a written report of the plan to the court.² Many federal districts prefer or require a joint case management statement rather than separate filings, even where the parties disagree. Where agreement is not possible on a point, the joint statement should present each side’s position on that disputed issue.

Initial Disclosures Run Alongside It

Separate from the statement itself, federal rules require each party to make initial disclosures within 14 days after the Rule 26(f) conference.² These disclosures happen automatically. No one has to ask. You must provide:

The name, address, and phone number of anyone likely to have relevant information you may use to support your claims or defenses, along with the subjects they know about.
A copy or description of all documents and electronically stored information in your possession that you may use to support your position.
A breakdown of each category of damages you are claiming, with the underlying documents available for inspection.
Any insurance policy that could cover part or all of a judgment against you.

A party served or joined after the initial conference has 30 days to make these disclosures.² The case management statement should confirm where things stand: whether disclosures have been exchanged, when they are scheduled, or whether any party has objected.

When to File and How to Serve It

Deadlines vary. In federal court, the written discovery plan report is due within 14 days after the Rule 26(f) conference.² State courts set their own windows, with 15 days before the conference a common deadline. Check the local rules or the notice setting the conference. Deadlines are enforced strictly.

Most courts now require electronic filing through a designated portal. Where paper filings are still accepted, the original goes to the clerk. Either way, you serve a copy on every other party at the same time you file, and then file a proof of service, a signed declaration confirming that the statement was delivered to all opposing parties, including the method and date. Skipping the proof of service is one of the easiest procedural missteps to avoid, and one of the most common.

What the Judge Does With It

The case management conference itself is usually brief. The judge reviews the filed statement, asks about gaps or disputes, and sets the case schedule. At least one attorney for each represented party must have authority to make stipulations and admissions about matters reasonably anticipated for discussion. If settlement is on the table, the court can require that a party representative with authority to settle be present or reachable by phone.¹ Showing up without the ability to agree to anything frustrates the judge and can invite sanctions.

The main output of the process is the scheduling order. At minimum, it sets deadlines to join new parties, amend pleadings, complete discovery, and file motions. Once the scheduling order is in place, modifying it requires showing “good cause.” Forgetting or running out of time will not do it. The deadlines in that order will govern the rest of the case, which is exactly why what you put in the statement matters. If you underestimate discovery needs or fail to flag a complex issue, you are stuck with the schedule the court sets based on your own representations.

What Happens If You Skip It or Show Up Unprepared

The sanctions are not trivial. Under Rule 16(f), the court can impose sanctions if a party fails to appear at the conference, shows up substantially unprepared, or disobeys a scheduling order.¹ Available penalties include:

Prohibiting a non-compliant party from introducing certain evidence or supporting designated claims.
Striking part or all of a party’s complaint or answer from the record.
Staying proceedings until the party complies.
Dismissing claims or entering default judgment in extreme cases.
Treating the failure as contempt of court.

On top of any of those, the court must order the non-compliant party or attorney to pay the opposing side’s reasonable expenses, including attorney’s fees, unless the non-compliance was substantially justified or an award would be unjust.¹ That “must” is not a typo. The fee-shifting is mandatory in the default case, not discretionary. Treating the case management statement as a formality is one of the more expensive mistakes a litigant can make.

1
LII / Legal Information Institute. Federal Rules of Civil Procedure Rule 16 – Pretrial Conferences; Scheduling; Management
2
LII / Legal Information Institute. Federal Rules of Civil Procedure Rule 26 – Duty to Disclose; General Provisions Governing Discovery
3
Federal Judicial Center. Joint Case Management Statement and Proposed Order