2. Discuss resolution through settlement;
3. Arrange for the initial disclosure of information by both sides as required by Rule 26(a)(1) including:
b. a list of certain documents described in FRCP 26(a).
5. Select an alternative dispute resolution (“ADR”) process: mediation, early neutral evaluation or settlement conference (discussed later in this Handbook);
6. Prepare and file a joint written report outlining the discovery plan.


