Practical Advice on the Management of Complex Litigation

Rule 26(f) of the Federal Rules of Civil Procedure serves as a powerful guide to the management of complex litigation because many judges and attorneys focus on this rule when managing such litigation. Indeed, Rule 26(f) provides a checklist of “things” to think about in whichever court, state or federal, complex litigation is pending. In turn, Rule 26(f) lays a foundation for the initial scheduling order that the assigned judge will issue under Rule 16(b). This article will provide some practice pointers for parties who are involved in complex litigation and the attorneys who appear on their behalf.