The Stipulated Case Management Order (“SCMO”) available for download from this site is the product of more than two-and-one-half years’ work by an ABTL statewide task force, led by former L.A. Chapter president Alan E. Friedman of Jones Day and the Honorable Victoria Chaney of the Los Angeles Superior Court, Complex Court. The SCMO is a “check-the-box menu” of case management and discovery procedures and protocols, designed specifically with business cases in mind. It provides a ready template litigants can use or adapt to streamline case management and discovery, avoid unnecessary discovery disputes, lower the cost of resolving any discovery disputes, and facilitate settlement by early resolution of important threshold issues.
The SCMO draws heavily on the experience and expertise of complex court judges in Northern and Southern California, several of whom helped formulate the SCMO and commented on successive drafts. It has been endorsed by the statewide Board of Governors of the ABTL, the Litigation Section of the Los Angeles County Bar Association, and the Consumer Attorneys Association of Los Angeles, among other groups.
The SCMO contains procedures for both two-party and multiparty cases. It contemplates the parties will meet and confer early on how they want case management and discovery to proceed, will select and adapt desirable procedures from the SCMO menu, and will supplement and discard as they see fit. They will then present the resulting SCMO to the court at a status conference for approval and implementation.
The SCMO is intended to be a “living” document. It can be dowloaded in Word™ format for easy use and adaptation, or as a .pdf file for viewing only. Users are encouraged to forward comments and suggestions about the SCMO to the current Chair of the Courts Committee of the Los Angeles Chapter of the ABTL, the current ABTL President, or the ABTL Executive Director.