Hard At Work Camp Lejeune Lawyers Make Major Headway in Moving Claims Forward
See below for the proposed case management order
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF NORTH CAROLINA
SOUTHERN DIVISION
No. 7:23-CV-897
IN RE: )
CAMP LEJEUNE WATER LITIGATION ) CASE MANAGEMENT
THIS ORDER RELATES TO: ) ORDER NO. 2
ALL CASES )
The undersigned Judges (“Court”), having appointed Plaintiffs’ Lead and Co-Lead
Counsel (together, “Plaintiffs’ Leadership”) to fairly, effectively, and efficiently represent the
interests of all Plaintiffs and to work collaboratively with counsel for the Defendant United States,
enters this Order in the interest of the just, speedy, and inexpensive determination of issues in this
litigation.
I. Preamble
The Court expresses its expectation that professionalism, courtesy, and civility will
continue throughout these proceedings. Federal Rule of Civil Procedure 42(a) provides that “[i]f
actions before the court involve a common question of law or fact, the court may: (1) join for
hearing or trial any or all matters at issue in the actions; (2) consolidate the actions; or (3) issue
any other orders to avoid unnecessary cost or delay.” The numerous actions filed under the Camp
Lejeune Justice Act (“CLJA”) “involve common question[s] of law or fact.” Fed. R. Civ. P. 42(a).
This Court accordingly has authority to consolidate these actions in whole or in part and/or to
adopt “other [case management] orders to avoid unnecessary cost or delay.” Id. In adopting these
orders, the Court finds it appropriate to draw by analogy on the procedures recommended for multi-
district litigation by the Manual for Complex Litigation Fourth (hereinafter “MCL 4th”).
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II. Rights and Privileges Preserved
The MCL 4th states that “[j]udicial involvement in complex litigation does not lessen the
duties and responsibilities of the attorneys. To the contrary, complex litigation places greater
demands on counsel in their dual roles as advocates and officers of the court. The complexity of
legal and factual issues makes judges especially dependent on the assistance of counsel.” MCL
4th, supra, § 10.21. The Court therefore notes that cooperation by and among Plaintiffs’ counsel
is essential for the orderly and expeditious resolution of this litigation. The communication of
information among and between Plaintiffs’ counsel shall not be deemed a waiver of the attorney-
client privilege and/or the attorney work product doctrine, if the privilege or doctrine is otherwise
applicable, and all of said persons shall maintain the confidentiality of said communications. This
provision does not limit the rights of any Party or counsel to assert the attorney-client privilege or
attorney work product doctrine. Nor does this provision expand or create a protection or privilege
that the Party does not otherwise already enjoy.
III. Applicability of Order
The provisions of this Order shall govern the practice and procedure in the individual
actions filed in this Court under the CLJA.
IV. Pretrial Coordination
The civil actions governed by this Order, whether previously filed or to be filed in the
future, shall be consolidated under Federal Rule of Civil Procedure 42(a) for purposes of
determining common questions of fact and law to actions under the CLJA. The adjudication of
common questions of law or fact shall not operate to deny any Party the opportunity to raise non-
repetitive issues that uniquely affect individual cases.
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A. Master Docket and File
The Clerk will continue to maintain a master docket case file under the style “In re Camp
Lejeune Water Litigation” and the identification “No. 7:23-CV-897.” Only Plaintiffs’ Leadership
and United States shall be permitted to file in the master docket. All orders, pleadings, motions,
notices, and other documents will, when filed and docketed in the master docket case file, be
deemed filed and docketed in each individual case that is on file to the extent applicable.
B. Individual Dockets
Each individual Plaintiff case shall maintain its own individual docket and remain assigned
to a single Judge of this District. Each Judge assigned to cases on an individual docket shall retain
the inherent authority to manage such cases, subject to determinations made on the master docket.
C. Captions and Separate Filings
Orders, pleadings, motions, notices, and other documents filed in the master docket will
bear a caption similar to that of this Order. If generally applicable to all consolidated actions, they
shall include in their caption the notation that they relate to “ALL CASES” and be filed and
docketed only in the master file. Documents that are intended to apply only to a particular case or
group of cases (for example, cases set for trial) but that are nonetheless appropriately filed on the
master docket (see Part VII, infra) will indicate in the caption the case number(s) of the case(s) to
which they apply by the words “This document relates to: [individual case(s), group of cases, as
identified by this Court's case number(s)].” Documents of this nature should be filed both in the
master case file and the specified individual case files.
D. Stay
All cases on individual dockets asserting any CLJA claim shall be stayed pending selection
of Plaintiffs for discovery and trial and further orders of this Court, except as provided otherwise
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in this Order. Counsel for the Defendant need not file Notices of Appearance or responsive
pleadings in stayed individual cases, subject to further Order of the Court.
V. Regular Status Conferences
The Court will hold regular status conferences. The first conference shall be held on a date
amenable to the Court. In addition, each undersigned Judge may also hold additional status
conferences as needed for individual cases.
Lead Counsel, the Government Liaison, Co-Lead Counsel, Liaison Counsel, and/or their
designees, and counsel for the Defendant will be designated to argue motions and actively
participate in status conferences and will appear in person. Plaintiffs’ Lead Counsel, Co-Lead
Counsel, and Liaison Counsel may attend any status conference, hearing, or other proceeding in
this matter even if not designated to argue a particular motion or issue.
Except for the first conference, Lead Counsel, the Government Liaison, and/or their
designees must meet and confer with counsel for Defendant before each status conference. They
must then submit a joint status report five (5) business days before the conference. This joint status
report should be filed via ECF and may include any items or issues that may be the subject of
pretrial conferences under Fed. R. Civ. P. 16(c)(2), and should include (i) an update on the number
of cases filed in the District; (ii) a status on the stipulations entered into between the Parties since
the last status conference; (iii) a summary of the discovery conducted since the last status
conference; and (iv) any other issues that the Parties wish to raise to the Court. If the Parties have
differing views on issues raised to the Court, their respective positions on each issue should be set
forth in the report.
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VI. Master and Short Form Complaints and Defendant’s Answer
The Court orders Plaintiffs’ Leadership to file a Master Complaint no later than seven (7)
days after the date of this Order. The Master Complaint will contain allegations that would be
suitable for adoption by reference in individual cases. All individual Plaintiffs shall use the Short
Form Complaint to commence their actions, which will allow the Parties to assess which portions
of the Master Complaint apply in each individual action. Individual plaintiff-specific information
to be included in the Short Form Complaint is attached to this Order, which has been negotiated
between Plaintiffs’ Lead Counsel and counsel for the Defendant to assist in assessing the
Discovery Plaintiff pool (see Part XII.A, infra). Any Plaintiff who filed a Complaint in this Court
prior to the filing of the Master Complaint shall file a Short Form Complaint in the Plaintiff’s
individual docket within forty-five (45) days of this Order.
The Short Form Complaint may be filed without a JS 44 civil cover sheet and without the
disclosure form ordinarily required by Local Rule 7.3(a). By filing a Short Form Complaint,
plaintiffs’ counsel is deemed to have appeared and submitted to the jurisdiction of this Court. For
purposes of efficiency, Plaintiffs’ counsel are required to file a Notice of Appearance or Notice of
Special Appearance only in counsel’s first filing. Similarly, Plaintiffs’ counsel not admitted to
practice before this Court are required to file the pro hac vice motion attached to the Court’s April
24th order only once. These lawyers will be deemed admitted pro hac vice in all subsequent CLJA
cases provided they follow ordinary procedures to pay the Camp Lejeune Justice Act Pro Hac Vice
Fee in each case.
Notwithstanding any Local Rule to the contrary, all Short Form Complaints are to be filed
in the Southern Division of this District.
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The Defendant shall file a Responsive Pleading to the Master Complaint within forty-five
(45) days of the filing of the Master Complaint. Defendant shall not be obligated to answer the
allegations in the Short Form Complaints. In any individual case filed by a Discovery Plaintiff in
which Defendant intends to assert an affirmative defense that is not already identified in its
Responsive Pleading to the Master Complaint, Defendant will provide notice of such affirmative
defense to Plaintiffs’ Leadership in a timely manner so as not to prejudice the Plaintiff.
VII. Motions Practice
All motions that are currently pending, except those seeking preservation of evidence under
Federal Rule of Civil Procedure 27, in any actions asserting CLJA claims are DENIED WITHOUT
PREJUDICE and with leave to refile in accordance with the procedures of this Order. Motions
raising global issues in the litigation may be filed by Plaintiffs’ Leadership or counsel for the
Defendant in the Master Docket after counsel have met and conferred regarding the motion.
No motions will be filed or discovery or other action or work in this litigation undertaken
by or on behalf of any individual Plaintiff, including pro se plaintiffs, except with permission from
Plaintiffs’ Leadership or leave of Court for good cause shown. Provided leave of Court or
permission is obtained, non-repetitive positions that uniquely affect an individual Plaintiff shall
not be filed in the master docket but shall instead be filed in the Plaintiff’s individual case.
VIII. Pretrial Orders
Plaintiffs’ Leadership and counsel for the Defendant will provide to the Court proposed
pretrial orders for the following issues, within fifteen (15) days of the Court’s Order: (1) a
Preservation Deposition Order; (2) a Deposition Protocol Order; (3) a Protective Order for
Protection of Privileged Information; and (4) a Protective Order for Protection of Confidential
Information. Within thirty (30) days of the Court’s Order, Plaintiffs’ Leadership and counsel for
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the Defendant will provide to the Court a proposed pretrial Electronic Discovery Order. If the
Parties cannot reach agreement on any of the orders, competing orders must be submitted along
with supporting memoranda of no more than ten (10) double-spaced pages.
IX. Stipulations
The Court believes that stipulations regarding certain issues will streamline the discovery
process and the overall efficiency of this case, including but not limited to stipulations regarding
the findings of scientific and environmental studies and the authenticity of government and
medical records. To this end, the Court orders the Lead Counsel, the Government Liaison, and/or
their designees to meet and confer with counsel for the Defendant at least on a monthly basis
regarding stipulations and to report to the Court regarding the progress on stipulations at each
status conference.
X. Self-Authentication and Admissibility of Certain Records
All government records, documents, data and studies (including, but not limited to, those
within the custody and control of Defendant or any government agencies, hospitals, departments
or other similar entity) are self-authenticating and admissible subject to relevance and/or Federal
Rule of Evidence 403 grounds, absent a specific dispute as to authenticity or admissibility and
including a notice of such dispute prior to the close of fact discovery.
Any medical records from an individual Plaintiff’s private health care providers are self-
authenticating and admissible, subject to relevance and/or Federal Rule of Evidence 403 grounds,
absent a specific dispute as to authenticity or admissibility and including a notice of such dispute
prior to the close of fact discovery.
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XI. Discovery and Trial Plan
PLAINTIFFS’ PROPOSAL
The Court recognizes the significant burden created by the number of cases already filed
and expected to be filed and the costs that Plaintiffs’ Leadership must advance to be able to
fulfill its responsibilities. The Court also recognizes that there are matters of fact that may be
common to all claimants, and that Plaintiffs’ Leadership is permitted to engage in general
discovery upon entry of this Order.
The Court expects the Parties to conduct discovery in an efficient manner in order to begin
trying cases promptly. The Court further believes that staging discovery and trials by “tracks” of
diseases is the most efficient way to advance the litigation and support a global resolution of CLJA
claims. The Court believes that holding multi-plaintiff trials, grouped by disease (or combinations
of diseases) is appropriate under the Federal Rules of Civil Procedure and promotes efficient
resolution of these matters.
A. Procedures for Track 1 Trials
i. Trial preparation should begin promptly regarding a selected Discovery
Pool, which shall be composed of cases in which the Plaintiffs allege that
they contracted 1) bladder cancer, 2) kidney cancer, 3) leukemia, 4)
Parkinson’s disease, or 5) non-Hodgkin’s lymphoma as a result of exposure
to contaminated water at Camp Lejeune. The selection of these cases does
not reflect any assessment of the merits of these or other claims but, rather,
is intended to focus on injuries for which early trials may help promote early
resolution for common injuries.
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ii. Discovery Pool Eligibility:
a. To be eligible for selection in the Discovery Pool a Plaintiff: 1) must
have filed his/her Short Form complaint within thirty (30) days of the
filing of the Master Complaint; and 2) not opted out of the Discovery
Pool as set out below.
b. Plaintiffs’ Leadership is responsible for overseeing and directing the
discovery and trials of plaintiffs who are selected for early discovery
and trial pursuant to this Order. If any
Plaintiff chooses not to proceed in a manner consistent with the above,
such individual can remove themselves from consideration of selection
into the Discovery Pool by notifying Plaintiffs’ Leadership and counsel
for the United States within forty-five (45) days of the filing of the
Master Complaint.
iii. Selection of “Track 1 Discovery Plaintiffs”
a. Within sixty (60) days of the filing of the Master Complaint, for each
illness listed in subsection XII.A.i, Plaintiffs’ Leadership and the
Defendant will each select 10 Plaintiffs to be included in the Discovery
Pool. If less than 20 Plaintiffs for an individual disease are eligible for
selection, all Plaintiffs alleging that disease shall be selected.
b. The selected Plaintiffs out of the Discovery Pool shall be designated as
“Track 1 Discovery Plaintiffs.”
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iv. Track 1 Discovery
a. Fact discovery in every Track 1 Discovery Plaintiff’s case will begin
immediately upon selection of the Track 1 Discovery Plaintiffs.
b. Within thirty (30) days of the filing of the Master Complaint, the Parties
shall submit to the Court an agreed upon plan or competing proposals
for a Discovery Pool Profile Form, which shall streamline written
discovery regarding the Track 1 Discovery Plaintiffs.
c. Each Track 1 Discovery Plaintiff shall complete the Discovery Pool
Profile Form within forty-five (45) days of it being finalized or their
selection as a Track 1 Discovery Plaintiff, whichever is later.
d. Absent a showing of good cause or agreement of the Parties, Defendant
shall be allowed to take no more than three (3) fact depositions (in
addition to treating physicians) for any individual case.
e. Plaintiffs and Defendants shall disclose their expert witnesses within
forty-five (45) days of the selection of Track 1 Discovery Plaintiffs. At
the time of disclosure, the Parties shall provide two dates on which the
expert is available for deposition.
f. Within fifteen (15) days of the Parties’ disclosure of experts, Plaintiffs
shall name any rebuttal experts.
g. The Parties may take the deposition of any individual disclosed as an
expert witness under Fed. R. Civ. P. 26(a)(2)(B) & (C).
h. Absent agreement of the Parties or a subsequent Order of this Court,
depositions shall be conducted pursuant to the Federal Rules of Civil
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Procedure. The deposition of a witness may be used for any purpose
appropriate under the Federal Rules of Civil Procedure and Federal
Rules of Evidence for any Discovery Plaintiff’s case. Expert discovery
will close sixty (60) days before trial.
i. Fact discovery shall end thirty (30) days prior to trial. Any trial
depositions may be taken, absent good cause, within ten (10) days prior
to trial.
v. Motion Practice Specific to Track 1
a. At the appropriate time, the Court and the Parties shall discuss the
pretrial schedule for submission of dispositive motions and for any other
pretrial motions or other matters regarding Track 1 Discovery Plaintiffs.
vi. Track 1 Trials
a. The Parties should be prepared to commence trials for some of the above
diseases beginning in the first quarter of 2024. To accomplish this, the
Track 1 discovery dates for certain Plaintiffs selected for early trials may
be shortened.
b. Within thirty (30) days after the deadline to complete Discovery Pool
Profile Forms, the parties shall submit to the Court an agreed upon plan,
or competing proposals for, the specific trial procedures for conducting
multi-plaintiff trials for the Track 1 Discovery Plaintiffs, or a subset of
those Plaintiffs.
c. Notwithstanding the above, each member of this Court will be
responsible for scheduling procedures for the trials in cases assigned to
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them, and any decisions regarding trial procedures, selection, structure,
timing, or any other issue(s) that are different from or contrary to the
provisions of this Order shall supersede this Order.
B. Procedures for non-Track 1 Diseases
i. To promote efficient litigation of the many additional cases that do not
involve Track 1 injuries, the Parties should be prepared to advance
additional trial tracks promptly after the selection of the Track 1 Discovery
Pool. These additional Tracks shall follow similar procedures to those
governing Track 1. Within sixty (60) days from the entry of this Order, the
Lead Counsel, Government Liaison, counsel for the Defendant and/or their
designees shall submit to the Court an agreed upon group, or competing
groups, of five (5) additional diseases for the purposes of Track 2. This
proposal may also suggest any potential revisions to the procedures
governing Track 1.
ii. Within thirty (30) days after proposing Track 2 conditions, the Lead
Counsel, Government Liaison, counsel for the Defendant and/or their
designees shall submit to the Court an agreed upon group or competing
groups of five (5) additional diseases for the purposes of Track 3. This
proposal may also suggest any potential revisions to the procedures
governing Track 1 and 2.
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UNITED STATES’ PROPOSAL
The Court recognizes the significant burden created by the number of cases already filed
and expected to be filed and the costs that Leadership must advance to be able to fulfill its
responsibilities. The Court also expects the Parties to conduct discovery in an efficient manner.
The Court further believes that staging discovery and trials by “tracks” of diseases is the most
efficient way to advance the litigation and support a global resolution of CLJA claims.
A. Procedures for Track 1 Diseases
i. Discovery regarding Initial Discovery Pool Plaintiffs will commence upon
entry of this Order in cases in which the Plaintiffs allege that they con-
tracted 1) kidney cancer, 2) leukemia, or 3) Parkinson’s disease as a result
of exposure to contaminated water at Camp Lejeune.
ii. Discovery Pool Eligibility: To be eligible for selection in the Discovery
Pool a Plaintiff: must have filed his/her Short Form complaint within
thirty (30) days of the filing of the Master Complaint.
iii. Plaintiffs’ Leadership is responsible for overseeing and directing the dis-
covery and trials of plaintiffs who are selected pursuant to this Order.
iv. Selection of “Track 1 Discovery Plaintiffs”:
For each of the Track 1 diseases, Plaintiffs Leadership and the Defendant
will each select 5 Plaintiffs out of the Discovery Pool. Ten (10) additional
Plaintiffs represented by counsel shall be selected randomly by the Court.
Within seven (7) days of the Court’s random selection, the Parties will
submit a joint status report identifying the selected Plaintiffs out of the
Discovery Pool.
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The selected Plaintiffs out of the Discovery Pool shall be designated as
“Track 1 Discovery Plaintiffs” in a “Track 1 Order” to be issued by the
Court.
v. Rules Governing Discovery and Pretrial for Discovery Pool Plaintiffs
a. Fact discovery in every Track 1 Discovery Plaintiff’s case may
begin immediately upon entry of the Track 1 Order.
b. Absent a showing of good cause or agreement of the Parties,
Defendant shall be allowed to take no more than three (3) fact
depositions for any individual case (with the exception of treating
physicians). Absent a showing of good cause or agreement of the
Parties, Plaintiffs shall be allowed to collectively take no more
than 20 depositions of a current or former government employees
and no more than 10 depositions of any other fact witness. Absent
a showing of good cause or agreement of the Parties, Plaintiffs will
be unable to depose a current or former government employee
more than one time.
c. The parties will complete fact discovery within 120 days of the
Track 1 Order. Within 45 days of completion of the fact
discovery, Plaintiffs shall disclose their expert witnesses under
Fed. R. Civ. P. 26(a)(2)(B) & (C)). Within 45 days of the
Plaintiffs’ disclosures of their expert witnesses the Defendant shall
disclose its expert witnesses under Fed. R. Civ. P. 26(a)(2)(B) &
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(C)). Within 90 days of the Defendants’ disclosure of its expert
witnesses, expert discovery will close.
d. Absent agreement of the Parties or a subsequent Order of this
Court, depositions shall be conducted pursuant to the Federal Rules
of Civil Procedure. The deposition of a witness may be used for
any purpose appropriate under the Federal Rules of Civil
Procedure and Federal Rules of Evidence for any Discovery
Plaintiff’s case.
f. At the appropriate time, the Court and the Parties shall discuss the
pretrial schedule for submission of dispositive motions and for any
other pretrial motions or other matters.
e. At the appropriate time, the Court and the Parties shall discuss the
selection of a certain Track 1 Discovery Plaintiff or Plaintiffs for a
Bellwether Trial or Trials.
B. Procedures for Track 2 Diseases
i. Track 2 Discovery Disease Plaintiffs will consist of plaintiffs claiming (1)
prostate cancer or (2) breast cancer as a result of exposure to contaminated
water at Camp Lejeune.
ii. Within 90 days of the date of this Order, Plaintiffs shall disclose an expert
opinion or opinions demonstrating that chemicals in the Camp Lejeune
water are capable of causing the disease as a matter of general causation.
The Plaintiffs shall supply a disclosure for their experts meeting the re-
quirements of Fed. R. Civ. P. 26(a)(2)(B).
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iii. Within 45 days of the Plaintiffs’ disclosure, the Defendant shall disclose
its expert opinions on the general causation issue.
iv. At the appropriate time the Court and the Parties shall discuss the schedule
for submission of dispositive motions or trial on the general causation is-
sue.
v. If general causation is established, the parties and the Court will select
Track 2 Discovery Plaintiffs for a Track 2 Discovery and Trial Schedule.
C. Procedures for Track 3 Diseases
i. Track 3 Discovery Disease Plaintiffs will consist of plaintiffs claiming dis-
eases that appear in fewer than 15 filed cases based on the Short Form
Complaints that are filed forty-five days after the filing of a Master Com-
plaint. The Court shall randomly select twenty of these cases.
ii. Within 90 days of the date of this Order, Plaintiffs in Discovery Track 3
must disclose an expert opinion under oath that the claimant’s disease was
caused by exposure to chemicals in the water at Camp Lejeune. The
Plaintiffs shall supply a disclosure for these experts meeting the require-
ments of Fed. R. Civ. P. 26(a)(2)(B).
iii. Within 30 days after the disclosure of expert opinions for Discovery Track
3 Plaintiffs, the parties will propose a discovery and motions schedule for
these Plaintiffs.
D. Additional Discovery Tracks
At the appropriate time, the Court and the Parties shall discuss the establishment of
additional discovery tracks for Plaintiffs not covered by Track 1, Track 2 or Track 3.
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XII. Ongoing Procedures for Global Resolution
Discussions regarding a global resolution are imperative and, therefore, the Parties shall
meet and confer regarding a process for global resolution and report status of those discussions to
the Court within thirty (30) days from the entry of this or the date on which the first Joint Status
Report is due, whichever is earlier.
XIII. Other Matters
A. Common Benefit
The Administrative and Common Benefit Committee shall submit a proposed protocol
within thirty (30) days of this Order, which will establish further rules and procedures beyond
those contained in the Court’s Order appointing Plaintiffs’ Leadership, dated July 19, 2023, ECF
No. 10, that govern eligibility, record-keeping, submission, and reimbursement of costs and fees
incurred for the common benefit of all Plaintiffs.
B. Litigation-Management Database
Plaintiffs’ Leadership and counsel for Defendant shall meet and confer on and propose to
the Court a litigation-management database within sixty (60) days from the entry of this Order.
C. Amendment of this Order
The Parties will meet and confer to recommend adjustments to this Case Management
Order provision should the Plaintiffs’ Leadership Group or the Defendant determine that it has
caused prejudice to either party.
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SO ORDERED this _____ day of __________________, 2023.
RICHARD E. MYERS II TERRENCE W. BOYLE
Chief United States District Judge United States District Judge
LOUISE W. FLANAGAN JAMES C. DEVER III
United States District Judge United States District Judge
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