Court document · Commercial Litigation & Dispute Resolution
Rule 26(f) discovery-plan report
Joint report of the parties' Rule 26(f) conference for a United States district court, covering disclosures, phasing, ESI, privilege and the orders they will ask for under Rules 26(c) and 16(b).
- Kind
- Court document. A document filed or served in a court or tribunal.
- Where it applies
- United States
- AI use
- Yellow You and the tool draft together, with you directing. You check every statement you rely on.
- Law stated as at
- 22 October 2026
- Status
- Maintained. Checked on 22 October 2026 against the 6 authorities it cites, for United States.
- Version
- 1
- Source
- Written for this library
When to use it
Use after the parties have actually conferred under Rule 26(f), and before the report is due. Do not file it as a substitute for the conference. Check the district's local rule and the judge's order for an earlier deadline or a required form.
Used for these tasks
- Review the discovery set and draft a production issues list
- Summarise discovery for privilege review with technology-assisted review
- Build an issue-to-document evidence table
- Investigate AI tools for document collation as ordered by the court
Each task page says how far AI may help with the task and what the lawyer must review.
How AI may be used
AI may assemble the report from the conference notes and the pleadings. The lawyer settles every position that will be submitted to the court.
AI may
- Turn the conference notes into the headings in Rule 26(f)(3), and mark each item agreed or disputed
- List initial-disclosure names and document categories the lawyer has already identified, with the source note
- Flag a heading the conference notes do not cover, including preservation, form of ESI, and privilege timing
AI must not
- Must not invent a party position, a date, or an agreement that is not in the conference notes
- Must not sign, file, or serve the report
- Must not drop in a case citation the lawyer has not opened
The lawyer checks
- Every disputed point is stated as a proposal, not as a joint position
- Dates fit Rule 16(b)(2) and any shorter local deadline the lawyer has checked
- Initial disclosures stated in the report match what the client can actually serve
Method: how the Green, Yellow and Red levels are decided. This is guidance for planning, not legal advice.
Read the full text
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- read the whole precedent, with its drafting notes beside it;
- copy it, or download it as a Word file or Markdown;
- add it to your firm’s knowledge base, so colleagues can find it;
- let the AI tools you connect read it from that knowledge base.
The summary, the law it rests on and the AI-use guidance above stay public. Privacy.
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