Rule 3.724.Duty to meet and confer

Rule 3.724 sets a deadline and a purpose. Unless the court sets a different schedule, the parties must sit down together — in person or by telephone — no later than 30 calendar days before the initial case management conference. The point is to have the parties do some of the groundwork themselves, so the conference isn’t the first moment anyone talks about the case’s real issues.

The rule spells out what belongs on that conversation’s agenda: resolving discovery disputes and setting a discovery schedule, flagging anticipated motions and trying to resolve them informally, sorting out which facts and issues are contested and which aren’t, seeing whether claims or defenses can be narrowed, gauging whether settlement is realistic, and comparing trial availability. It also folds in every topic listed separately in rule 3.727, so the meet-and-confer session doubles as preparation for the conference itself.

A large chunk of the rule is devoted to electronically stored information specifically — preservation, the form and timing of production, scope, how privilege and work-product claims will be handled, confidentiality and trade-secret protection, and how production costs get divided. Given how much litigation now runs through email, databases, and other electronic records, the rule treats an ESI plan as its own required subject rather than an afterthought.