Rule 3.750.Initial case management conference

Complex cases — the kind involving many parties, coordinated proceedings, or unusually difficult issues — don’t fit neatly into the general case management chapter built around rules 3.721 through 3.730. Rule 3.750 gives them their own initial case management conference instead, one the court should hold with every party represented at the earliest practical date rather than on the general chapter’s standard timeline.

The subjects the court should consider at that conference reach further than the general list. Some track ordinary case posture — service, added parties, amended pleadings, and deadlines for remaining pleadings. Others are tools distinctive to complex litigation: whether to sever, consolidate, or coordinate with other actions, whether to appoint liaison or lead counsel, whether a special master should be appointed, whether discovery should be stayed until all parties are in the case, and whether to set up a case-based website for sharing contact information. Still others focus on discovery and motion planning — a discovery schedule, lists of deponents and deposition subjects, document exchange and a possible electronic depository, and a deadline for dispositive motions.

The rule states its own purpose plainly: the conference exists to surface the essential issues in the litigation early and to head off discovery that would otherwise become unnecessary and burdensome as the case develops. To get there, the court may order counsel to meet privately before the conference and prepare a joint statement covering what’s already agreed, what the court needs to decide, and the major legal and factual issues in play — a more court-directed version of the meet-and-confer duty that rule 3.724 imposes automatically in general civil cases.