CIVIL BEST PRACTICES
July 1, 2000
The report to the Supreme Court of the New Jersey Judiciary Strategic
Planning Committee, issued March 31, 1998, stressed the themes of unification
and accountability. The committee identified three goals that must be attained
before New Jersey can achieve a fully unified court system. The third of these
goals calls for the standardization of operations to provide a uniform system
of justice and consistency in quality of service statewide. The committee took
the position that, in order to attain this goal, the Judiciary should, among
other things, "develop statewide consistency in case management systems for the
Civil, Criminal, Family, and Probation Divisions."
In accordance with the report of the Strategic Planning Committee, and
at the direction of Chief Justice Deborah T. Poritz, the Judicial Council, at
its two-day retreat in April 1998, charged the Conference of Civil Presiding
Judges with developing a standard, statewide civil case management system. This
charge was memorialized in the Chief Justice's letter of June 26, 1998 to the
Hon. Robert E. Guterl, chair of the Conference of Civil Presiding Judges.
Specifically, the letter directed the Conference, among other things, to make
recommendations concerning the development of operating standards for a
statewide civil case management system, including assignment to tracks,
discovery practice, dismissals, arbitration practice, settlements, motion
practice, and trial calls.
The Conference met monthly to meet this charge, and in the process
sought the views of the State Bar, various other statewide bar associations,
the county bar associations, the Civil Practice Committee and the Conference of
Civil Division Managers. The Conference of Civil Presiding Judges' report was
issued in March 1999 and contained a total of 66 individual recommendations,
based on an identification of "best practices", that addressed the entire civil
caseflow process from initial track assignment through trial management. The
report was published for comment in the April 5, 1999 issues of the New
Jersey Law Journal and New Jersey Lawyer. After considering the many
thoughtful comments that were submitted, the Conference amended a number of its
recommendations and delivered the revised report to the Supreme Court for
consideration at its June 22, 1999 Administrative Conference.
Many of the comments received tended to focus on the exceptional
circumstances that may legitimately arise to delay some cases. What the Civil
Presiding Judges attempted to do was to build a standard system, based on best
practices, that will provide the flexibility needed to deal with true
exceptions, i.e., problems that are beyond an attorney's control. The
Civil Presiding Judges recognized that the court must retain the discretion to
address such exceptions, but would not build a standard, statewide system
The Supreme Court thoroughly reviewed the Civil Presiding Judges'
report, all the comments its publication generated and the revisions made to
accommodate many of those comments. The Court approved the report, as revised,
in its entirety and directed the Civil Practice Committee to draft the
necessary rules and rule amendments to implement the "best practices"
recommendations. The Supreme Court approved the rules and rule amendments at
its Rules Conference on May 18, 2000, for adoption on September 5, 2000. Thus,
all cases filed on or after September 5, 2000 will be subject to the "best
practices" recommendations and the rules implementing these recommendations
What follows is a summary of the various recommendations, reference to
the implementing rules, and a brief discussion of what implementation will
involve, from a practical or operational perspective. Reference to the
particular recommendation as approved by the Supreme Court is provided when no
rule or rule amendment was deemed necessary for implementation, and a copy of
the approved recommendations is attached. In those instances in which the
language of the implementing rule does not precisely reflect that of the
corresponding recommendation, the language of the rule controls.
Section 1. Tracks - Assignment
For purposes of managing the voluminous civil
caseload, it is essential to break the caseload down into discrete categories.
Cases will be assigned to a track upon the filing of
the complaint. The track assignment is based on case type as noted on
side 2 of the Case Information Statement (CIS) and each track provides a
specific discovery period based on the presumed discovery needs of the case
types allocated to the particular track. See Rules 1:5-6 and
4:5-1; 4:5A-1, -2, -3; new CIS form.
The four tracks and the discovery period and case
types associated with each are:
Track I - 150 days' discovery
- 151 Name Change
- 175 Forfeiture
- 302 Tenancy
- 399 Real Property
- 502 Book Account
- 503 Commercial Transaction
- 505 Other Insurance Claim (including declaratory judgment actions)
- 506 PIP Coverage
- 510 UM or UIM Claim
- 511 Action on a Negotiable Instrument
- 599 Contract
- 801 Summary Action
Track II - 300 days' discovery
- 305 Construction
- 509 Employment (other than CEPA or LAD)
- 602 Assault and Battery
- 603 Auto Negligence - Personal Injury
- 605 Personal Injury
- 610 Auto Negligence - Property Damage
- 699 Tort - Other
Track III - 450 days' discovery
005 Civil Rights
- 301 Condemnation
- 604 Medical Malpractice
- 606 Product Liability
- 607 Professional Malpractice
- 608 Toxic Tort
- 609 Defamation
- 616 Whistleblower/Conscientious Employee Protection Act (CEPA) Cases
- 617 Inverse Condemnation
- 618 Law Against Discrimination (LAD) Cases
Track IV - Active Case Management by Individual Judge/450 days'
- 156 Environmental Coverage Litigation
- 234 FRT Plywood Litigation
- 245 Actions under Federal Y2K Act
- 303 Mt. Laurel
- 508 Complex Commercial
- 613 Repetitive Stress Syndrome
- 701 Action in Lieu of Prerogative Writ
Mass Tort (Track IV)
- 240 Diet Drug
- 241 Tobacco
- 243 Latex
- 246 Rezulin
- 601 Asbestos
- 611 Breast Implant Cases
- 612 Blood-Clotting Serum
- If summary actions are not resolved on the return date, they are to
be case managed
With respect to particular case types:
Actions in lieu of prerogative writ. See R.
- Assigned to Track IV to ensure individual judge management, even
though most will not need 450 days' discovery
- An informal conference, by telephone or in chambers, must be held
within 30 days of joinder to determine factual and legal disputes, mark
exhibits, establish a briefing schedule, and if necessary, a discovery
- At least five days before the conference, parties shall submit a
statement of factual and legal issues and an exhibit list to the managing
- Complaint must be accompanied by certification that transcripts of
proceedings below have been ordered.
Complex Commercial Cases
- Assigned to Track IV to ensure that one judge handles the case from
filing through trial (absent exceptional circumstances).
Track Assignment Notice. See R. 4:5A-2.
The court will mail the Track Assignment Notice (TAN) to the plaintiff
with the docketed copy of the complaint or within 10 days of the filing of the
complaint. The TAN will advise plaintiff of the track, team, and judge to which
the case has been assigned.
- Track Assignment Notice shall be attached to, and served with, the
summons and complaint on all parties.
Changes of Track Assignment. See R. 4:5A-2.
It is possible to change track assignment either at the outset of a
case or as the case develops.
- Within 30 days of receipt of the Track Assignment Notice, the
plaintiff may apply to the court for a change of initial track assignment by
filing a certification of good cause.
- Any party other than the plaintiff seeking a change of initial track
assignment may file and serve a certification of good cause with its first
- Objections to the certification of good cause for change of track
assignment must be made within 10 days by responding certification.
- The designated pretrial or managing judge, or his or her designee,
should respond in writing, e.g., by letter or memo, advising of the court's
determination on the application for change of track assignment.
- Any party who is aggrieved by the court's determination on such
applications may seek relief by filing a formal motion within 15 days of the
entry of the order.
- Subsequent applications to change track assignment must be made on
formal motion and may be granted only on a showing of exceptional
- The court may sua sponte, at any time and on notice to the parties,
order a change of track assignment for good cause.
- Track assignment should not change to accommodate a party's (or the
parties') need for a longer discovery period; rather the party(ies) may apply
to the pretrial judge for an extension of the discovery end date, which may be
granted in accordance with R. 4:24-1. (Recommendation 1.15)
- Individual judge management may be available to cases on Tracks I,
II, and III, if the court determines it to be necessary, either on the request
of a party or sua sponte; this degree of management, however, should not result
in reassignment of the case to Track IV. (Recommendation 1.12)
- Cases that are administratively or procedurally complicated are not
necessarily Track IV cases; such cases should be placed and remain on the track
to which they are presumptively assigned based on case type. (Recommendation
Section 2. - Judicial Case Management/Calendaring
One goal of the best practices systems is to ensure that every case on
Tracks I, II and III is handled by the same "pretrial judge" from filing
through discovery, and for cases on Track IV by the same "managing judge" from
filing through trial, barring exceptional circumstances. See R.
- An example of "exceptional circumstances" may be Track IV mass tort
cases that have been centralized in one county for pretrial management, but
which may go back to the county of original venue for trial. (Recommendation
- A judge other than the designated pretrial or managing judge may
nonetheless handle a settlement conference in any case, and block scheduling of
settlement conferences (e.g., "settlement days" involving many cases
from a designated carrier) may continue. (See note following Recommendation
- The oversight of the designated pretrial judge in cases on Tracks I,
II and III does not necessarily extend beyond the track-allotted discovery
period plus 60 days. Thereafter, motions to extend discovery further are
handled by the Civil Presiding Judge or his or her designee. See
- Civil Presiding Judges retain the authority to assign particular
cases or classes of cases to particular judges for oversight of all pretrial
activity prior to the end of the track-allotted discovery period plus 60 days.
For example, a single pretrial judge may be designated to handle all medical
malpractice cases filed in the vicinage.
Track IV cases will receive early judicial intervention:
- An initial case management conference in all Track IV cases is to be
conducted within 60 days of joinder (except in prerogative writ cases, which
are governed by R. 4:69-4).
In cases on any track:
- The number of case management conferences is within the discretion
of the pretrial or managing judge.
- Case management conferences should not ordinarily be held after a
case is ready for trial.
- All decisions and directives issued at a case management conference
must be memorialized by court order, pursuant to R. 1:2-6.
Section 3. - R. 1:13-7 Dismissal
The current practice under R. 1:13-7 places a tremendous burden
on the civil system. Each month, staff must generate and mail (at 33¢
each) thousands of dismissal notices statewide. In response, attorneys must
prepare and the court must read thousands of affidavits stating why service has
not been effected. This goes on month after month until finally a case is
dismissed. The Civil Presiding Judges sought to remedy this costly and
labor-intensive practice while ensuring due process to the parties. Under the
best practices system, the dismissal procedure is streamlined. See
Rules 1:13-7 and 4:43-2.
- After four months of inactivity, the court will issue a notice to
counsel advising that the case will be dismissed without prejudice in 60 days,
unless one of the following occurs within that period:
-- an answer is filed with the court OR
-- proof of service is filed with the court OR
-- a motion is filed, showing exceptional circumstances why the case
should not be dismissed.
- If none of the above occurs in the 60-day period following the
notice, the case will be dismissed without prejudice and the order of dismissal
will be sent to the parties; thereafter, reinstatement may occur only on formal
motion, with notice to all parties.
- Cases in which default judgment has not been applied for within six
months of the entry of default will also be subject to the procedure.
- Dismissal under R. 1:13-7 may occur as to individual parties,
with the case continuing against remaining defendants.
Section 4. - Inactive Cases
The Rules of Court do not provide for the "inactivation" of cases, with
the exception of cases placed on the military list pursuant to R.
1:13-6. Accordingly, cases should be considered active and managed accordingly;
dismissed without prejudice when beyond the ability of the court to process; or
placed on the military list and monitored by the court. (Recommendation 9.0)
- Cases may be stayed by court order in certain circumstances, but
such cases will continue to age for statistical purposes. Example of situations
in which cases may be stayed include:
-- cases in which an appeal is pending;
-- civil forfeiture cases in which resolution of the underlying
criminal matter is still pending;
-- federal preemption of a cause of action brought in state court;
-- the case has been referred to mediation.
- In cases in which a party is in bankruptcy, the court may wish to
dismiss that party (without prejudice), and continue the case with the
Section 5. - Discovery
The present 150-day discovery period is rarely observed; attorneys are
routinely granted extensions and the discovery end date is rarely enforced.
Under the best practices system, only Track I cases are restricted to 150 days
of discovery. The lengthier discovery periods permitted cases on Tracks II, III
and IV, if enforced as intended, will actually result in less protracted
discovery than is now the case. Please note that for cases filed prior
to September 5, 2000, the new track-based discovery periods will not
Calculation of Discovery Period. See R. 4:24-1(d).
- Discovery runs from the date the first answer is filed or from 90
days after the first defendant is served, whichever is first.
Late Served and Newly Added Parties. See Rules 4:8-1 and
4:24-1(a) and (b).
- An originally named party who has been unable to be timely served
may seek an extension of discovery.
- Joinder of a new party extends the discovery period for 60 days,
which period may be reduced or enlarged by the court.
- A party filing a pleading that joins a new party to the action must,
within 20 days after service of the new party's pleading, serve a copy of all
discovery materials upon, or otherwise make such materials available to, the
new party. This language should be included in the order allowing joinder of
the new party.
Extension of Time for Discovery. See R. 4:24-1(c).
- Parties may extend the track-allotted discovery period up to 60
days, by consent.
- If parties do not agree, or if an extension greater than 60 days is
sought, a formal motion must be filed with the Civil Presiding Judge or his or
- Any such application for discovery may be granted for good cause
shown, and the order must describe the discovery to be engaged in and specify
the date by which discovery is to be completed.
- Absent exceptional circumstances, no discovery extension is to be
permitted once an arbitration or trial date is set.
With respect to the last point, the Civil Presiding Judges recognized
that the parties may conduct additional discovery by consent, even after an
arbitration or trial date is set. Such consensual discovery, however, must not
delay any proceeding date fixed by the court, nor will it be enforced by the
"Automatic" Discovery. See Rules 4:17-1, -2, -4.
- A defendant served with a complaint in a case type for which uniform
interrogatories have been adopted, is deemed to have been simultaneously served
with such interrogatories, and must serve answers to the appropriate uniform
interrogatories within 60 days after service of the answer to the
- The plaintiff is deemed to have been served with uniform
interrogatories simultaneously with service of defendant's answer to the
complaint, and must serve answers to the interrogatories within 30 days.
Non-Compliance with Discovery Request. See Rules 4:18-1,
4:19 and 4:23-5.
To relieve an aggrieved party from having to apply to the court to
compel certain discovery to which it is entitled, R. 4:23-5 procedures
are applied to non-compliance with discovery requests made under Rules
4:18-1 and 4:19.
- An aggrieved party may move to dismiss or strike the pleadings of a
party who does not comply with a request to produce, to inspect or to submit to
a mental or physical examination.
- As to physical or mental exams:
-- the adverse party may require the party whose physical or mental
condition is in controversy to submit to an exam by serving notice upon that
party, stating with specificity when, where and by whom the exam will be
conducted, as well as the nature of the exam and any proposed tests;
-- at least 45 days' notice of the exam must be provided;
-- a party seeking a protective order must apply therefor within the
45-day notice period;
-- reexamination may be made by consent, or if the party to be
reexamined does not consent, by court order.
Section 6. - Motions
The civil justice system is awash in motions. Well over 210,000 civil
motions are filed annually. Many of the best practices procedures are designed
to facilitate a more streamlined motion process.
Assignment of Motions. See R. 1:6-2.
Reserved Motion Decisions
- Civil Presiding Judges should be knowledgeable as to which motion
decisions are reserved, and address delays on a judge-to-judge basis, as
needed. The Civil Practice Committees of the county bar associations should be
encouraged to discuss with their Civil Presiding Judges problems with
long-reserved decisions. In addition, any attorney involved in a case in which
a decision on a motion has been reserved may make application to the Civil
Presiding Judge to have that motion decided on a timely basis. (Recommendation
Scheduling Motions/Oral Argument
- Motions must always be assigned a return date; if no return date is
indicated in the notice of motion, then the motion should be assigned to be
heard on the next available motion date. (Recommendation 5.1)
- Motions should not be adjourned without being assigned another
hearing date. (Recommendation 5.2)
- Oral argument on motions is to be permitted as R. 1:6-2 now
provides. (Recommendations 5.3)
- Oral argument will be confirmed by the court two days prior to the
return date. Confirmation shall be made to the moving party, whose obligation
it is to advise all other parties. (Recommendation 5.4)
N.B. This practice may become obsolete by the time the best practices
system is implemented in September 2000, as motion calendar/disposition/oral
argument status will be posted on the Internet.
- The practice of posting tentative motion decisions in advance of the
return date may be continued or implemented as a local prerogative.
- The court should make every effort to accommodate attorneys'
requests to schedule oral argument on motions at a particular time.
- The use of the telephone to hear oral argument should be encouraged,
and attorneys' requests for telephone argument should be accommodated where
possible. (Recommendation 5.7)
Section 7. - Trial Information Statement (TIS). See Rules
4:36-2 and 4:25-4; new TIS form.
If the overarching goal of best practices is to provide credible trial
dates then the TIS is the key to achieving that goal. The TIS is the mechanism
whereby attorneys advise the court that discovery is complete and the case is
ready to be scheduled for trial or arbitration. The TIS also requires attorneys
to designate, or confirm previously designated, trial counsel and to advise the
court of dates when they, their clients and their experts will be unavailable.
- Each party must file and serve a TIS within 10 days following the
end of the discovery period (including any extensions)
- The court will send a TIS reminder notice to each party 30 days
before the discovery end date
- The attorney must certify on the TIS that discovery is complete and
the case is ready to be scheduled for arbitration or trial.
- If discovery is not complete, an extension of discovery may be
sought, in accordance with R. 4:24-1(c).
Failure to File TIS
- If a party fails to file the TIS as required
-- designation of trial counsel will be deemed waived (even if
-- the court will assume that discovery is complete,
-- the case will be scheduled for arbitration or trial, and
-- no adjournment of the scheduled arbitration or trial date will be
granted for incomplete discovery, absent exceptional
Section 8. - CDR
The best practices system both standardizes the use of arbitration and
promotes increased use of mediation.
Arbitration. See R. 4:21A-1 et seq. and Uniform
Arbitration Statement of Facts Forms.
- Various Supreme Court Orders authorizing arbitration of cases beyond
what is required by statute will be terminated.
- The following cases on Track I, II and III will be subject to
-- all auto negligence cases, regardless of amount in controversy;
-- all personal injury cases, regardless of amount in controversy,
including product liability cases but excluding professional negligence cases;
-- all PIP cases;
-- all book account cases and actions on a negotiable instrument; and
-- all other contract and commercial cases that, after screening by
the teams, are deemed appropriate for arbitration (standardized screening
guidelines will be prepared).
- Cases on Track IV may be subject to arbitration within the
discretion of the managing judge.
- Counsel may apply to the court for a case's removal from mandatory
arbitration, pursuant to R. 4:2(A-1(c), if the case has been mediated,
remains unresolved and counsel believes that arbitration would be
- Arbitration hearing is to occur within 60 days of the end of
- Adjournments for failure to complete discovery are to be granted
only upon a showing of exceptional circumstances.
- Single arbitrators will hear all cases; the two-arbitrator panels
are to be discontinued.
- Parties are to exchange statements of factual and legal issues, in
the uniform forms provided as appendices to the Rules of Court.
- Failure to appear at a scheduled arbitration hearing shall result in
dismissal (as to plaintiff) or striking the answer, proceeding with the
arbitration and waiver of the right to trial de novo (as to
defendant), absent good cause.
- Trial de novo is to be held within 90 days of the filing of
the trial de novo request.
- Staff are expressly authorized to reject for filing a late trial
de novo request. See R. 1:5-6(c).
- The mandatory scheduling of arbitration in most civil cases should
not preclude the use of other CDR procedures at any time. (Recommendation
- Increased use of mediation at the earliest possible time in the
progress of a case should be encouraged. Mediation should be available at any
stage of the proceedings, either at the parties' request or on the court's
order, pursuant to R. 1:40-4. (Recommendation 7.3)
- Early mediation should be considered for all fee-shifting cases
(e.g., cases brought under the Law Against Discrimination) as well as
for all fund-in-court cases. (Recommendation 7.4)
Section 9. - Settlement Events. See R. 4:5B-3.
The best practices system seeks to encourage meaningful
settlement events. The term "settlement events" is intended to include judicial
settlement conferences and bar panels; it is not intended to include settlement
discussions with a judge or the day of trial.
- Except in individual judge-managed Track IV cases, the court may
mandate no more than one settlement event (with a judge or before a bar panel)
in advance of the trial date.
- The court should make every effort to accommodate attorneys'
requests for settlement events (i.e., a bar panel or a conference with
a judge) in advance of the trial date. (Recommendation 8.0)
Section 10. - Calendar Practiced/Trial Calls. See R.
The best practices system is intended to deliver standardized
calendaring and trial call procedures that should provide the court and the bar
with a high degree of certainty as to when cases will go to trial.
- Trial date (or at least trial week) certainty is the goal.
Scheduling and Noticing Cases for Trial
- As a matter of policy, no county shall hold an advance calendar call.
- Cases may be listed for trial call on the first three days of a
trial week. This is not intended to preclude other non-trial proceedings, such
as proofs and friendlies, from being listed for the remaining days.
- In no event should the number of cases listed during a trial week
exceed the number that a county can reasonably expect to reach in that week.
The rule of thumb is to call in about 15 cases per judge. (Recommendation
- The court will give all parties eight weeks written notice of the
initial trial date.
- If a case is not reached during the week in which the initial trial
date falls, it should be relisted for a trial date certain after consultation
- No case should be relisted sooner than four weeks from the initial
trial date without agreement of counsel.
- Counsel are to receive written notice of new trial dates for
This is intended to put a stop to telephone notice of rescheduled trial
dates, which makes the entire trial process unpredictable for attorneys,
litigants and witnesses.
Appearance of Attorneys
- On the day of the call, attorneys should be released by early
afternoon unless their cases are sent out, or can reasonably be expected to be
sent out, for settlement discussion or trial that day. (Recommendation
- Attorneys need not appear at trial calls subsequent to the initial
call for their case in the trial week unless the case can reasonably be
expected to be sent out for settlement discussion or trial on that subsequent
date. (Recommendation 10.2a)
Section 11. - Trial Adjournments. See Rules. 4:36-3(b)
Best practices calls for a standard procedure for requesting an
adjournment of a trial date.
How an Adjournment Request is Made
- Personal appearances to request trial adjournments shall not be
- Adjournment requests must be made in writing to the Civil Division
Manager, and must
-- state the reason for the request,
-- state that all parties have consented to the adjournment, AND
-- include a proposed trial date agreed upon by all
- If all parties do not consent to the adjournment or to a proposed
rescheduled date, or if the trial has already been adjourned once at a party's
request, the court will conduct a conference call with all parties to determine
if the case should be adjourned and, if so, when it should be rescheduled.
Why an Adjournment Request is Made
- Adjournment requests should generally be made only if an attorney,
party or witness is unavailable.
- No adjournment request for incomplete discovery should be made or
granted, barring exceptional circumstances.
- No adjournment request should be granted to accommodate a
dispositive motion returnable on or after the trial date.
When an Adjournment Request is Made
- Requests for adjournment must be made as soon as the need is known,
but in no event, absent exceptional circumstances, later than the Wednesday
preceding the Monday call.
Videotaping Unavailable Expert
- If the reason for the initial adjournment request was the
unavailability of an expert witness, no further adjournment request for that
expert's unavailability shall be granted.
- Previously unavailable expert shall be required to appear in person
or on videotape on the rescheduled trial date.
- If the trial was previously adjourned because of one expert's
unavailability, the court may direct that no further adjournments will be
granted for the failure of any expert to appear.
Section 12. - Trial Management. See Rules 4:25-7 and
4:35-4; New Pretrial Information Exchange form.
The best practices system seeks to ensure more effective trial
preparation by attorneys and more effective trial management by the court.
Pretrial Exchange of Information
- Seven days prior to the initial trial date, attorneys shall confer
and exchange information as prescribed on the Pretrial Information Exchange
form, which is included as an appendix to the Rules of Court.
- Prior to opening statements, attorneys shall submit to the trial
judge copies of any materials exchanged pursuant to R. 4:25-7, as well
-- any stipulations reached on contested procedural, evidentiary and
substantive issues; and, in jury trials,
-- special voir dire questions,
-- proposed jury instructions, with specific reference to the Model
Civil Jury Charges, if applicable,
-- a proposed jury verdict form that includes all possible verdicts
the jury may return.
- Failure to exchange and submit the required information may result
in sanctions, in the discretion of the trial judge.
- Attorneys are under a continuing obligation to report to the court
any stipulations reached during trial.
- Insofar as is practicable, all trials should be continuous and
uninterrupted, and should run for the full day as prescribed by R.
Bifurcation of Liability and Damages
- The court must be bound by R. 4:38-2 (b), which permits
consideration of bifurcation in individual cases only. No county is permitted
to implement or maintain a policy that calls for routine bifurcation of a
particular type of case. (Recommendation 12.2)
Section 13. - Civil Backlog Measures
Under current definitions, a civil case is in backlog if it is over
twelve months old. Redefinition of civil backlog measures was necessary if
civil statistics are to reflect the age of the civil caseload with any
accuracy. Accordingly, as of September 2000, backlog and inventory definitions
will be tied to the four case management tracks. Thus,
Track Backlog Measure
I (150 days' discovery) 12 months
II (300 days' discovery) 18 months
III (450 days' discovery) 24 months
IV (450 days' discovery) 24 months
Notices to the Bar Re Best Practices