Per Diem Preliminary Conference Coverage

Preliminary Conference Coverage

Setting the Discovery Schedule Right From the Start

The preliminary conference sets the discovery schedule that governs the rest of the case, which makes it one of the appearances firms least want to miss or mishandle — even though it's often scheduled with limited flexibility around a firm's existing calendar.

Preliminary conferences in Kings County Supreme Court establish deadlines for depositions, expert disclosure, note of issue filing, and other discovery milestones that shape the case going forward. Because these dates are typically set early in the litigation, before a firm has built its internal calendar around the matter, conflicts with existing commitments are common.

Our attorneys arrive prepared with your firm's proposed discovery timeline and any specific scheduling constraints you've flagged, so the preliminary conference order reflects your firm's actual availability and case strategy rather than defaulting to whatever the opposing party proposes.

The schedule set here becomes the baseline for every compliance conference that follows, so an attorney who understands your firm's actual capacity — including how it fits around other court appearances your firm is handling — can save you from an unrealistic timeline later.

What We Cover at a Preliminary Conference

• Appearing to establish the discovery schedule per your firm's proposed timeline
• Negotiating reasonable deadlines with opposing counsel on the record
• Flagging any case-specific scheduling constraints in advance
• Reporting the entered scheduling order back to your firm the same day
• Confirming the next compliance conference date, if set