(a) Generally. A party may file a motion to designate a case as complex.
(b) Time to File. A party may file the motion not later than 60 days after the initial response, or later for good cause.
(c) Factors. When exercising its discretion in deciding whether an action is complex under this rule, the court should consider the following factors:
(1) issues that will be time-consuming to resolve;
(2) management of a large number of witnesses or a substantial amount of documentary evidence;
(3) the need for significant expert testimony;
(4) any other factor that in the interests of justice warrants a complex designation or as otherwise required to serve the interests of justice.
(d) Effect of Designation. After designating a case complex, the court must conduct a scheduling conference at which it may enter orders concerning the scope and timing of disclosure and discovery. The court also may extend the time for parties to complete discovery under Rule 51 and must provide a minimum of 12 hours for trial.