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Case 1:05-cv-00896-WKW-VPM Document 6 Filed 01/06/2006 Page 1 of 3 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA SOUTHERN DIVISION E Q UAL EMPL O Y ME N T OPPORTUNITY COMMISSION, Plaintiff, v.
Case No.: 1:05-CV-896-T FACTORY CONNECTION, LLC, Defendant.
REPORT OF PLANNING MEETING
1.
Pursuant to Fed.R.Civ.P. 26(f), a meeting was held on January 6, 2006, and was attended by John Mark Graham on behalf of the plaintiff and Brian R. Bostick on behalf of the defendant.
2.
Pre-Discovery Disclosures. The parties will exchange by January 26, 2006 the information required by Local Rule 26.1.
3.
Discovery Plan. The parties jointly propose to the court the following discovery plan:
a.
Discovery will be needed plaintiff's claims and defendant's defenses:
b.
All discovery commenced in time to be completed by November 1, 2006.
c.
Maximum of 25 interrogatories by each party to any other party. Responses due 30 days after service.
d.
Maximum of 30 requests for production by each party to any other party. Responses due 30 days e.
Maximum of 25 requests for admission by each party to any other party. Responses due 30 days after service.
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Case 1:05-cv-00896-WKW-VPM Document 6 Filed 01/06/2006 Page 2 of 3 e.
Maximum of 8 depositions by plaintiff and 8 by defendant. f.
Each deposition limited to maximum of 7 hours (except plaintiff’s deposition and any 30(b)(6) deposition, which are limited to 8 hours) unless extended by agreement of parties.
g.
Reports from retained experts under Rule 26(a)(2) due: from plaintiff by June 1, 2006; from defendant by September 1, 2006.
h.
4.
Supplementation under Rule 26(e) due by 30 days prior to discovery cutoff.
Other items. The parties do not request a conference with the court before entry of the scheduling order.
a.
The parties request a pretrial conference after any dispositive motions have been ruled upon.
b.
Plaintiff should be allowed until April 1, 2006 to join additional parties and amend the pleadings. c.
Defendant should be allowed until May 1, 2006 to join additional parties and amend the pleadings. d.
All potentially dispositive motions should be filed by October 1, 2006.
e.
Settlement cannot be evaluated prior to the completion of substantive discovery. Evaluation of the suitability of this case for mediation under the Alternative Dispute Resolution Plan cannot be made until discovery has taken place.
f.
Final lists of witnesses and exhibits under Rule 26(a)(3) should be due:
from plaintiff by 30 days prior to trial; from defendant by 20 days prior to trial.
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Case 1:05-cv-00896-WKW-VPM Document 6 Filed 01/06/2006 Page 3 of 3 g.
Parties should have 10 days after service of final lists of witnesses and exhibits to list objections under Rule 26(a)(3). h.
The case should be ready for trial by December of 2006 and at this time is expected to take approximately 3 days. Date: January 6, 2006.
Respectfully submitted, /s Brian R. Bostick Brian R. Bostick (BOS015) OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
One Federal Place, Suite 1000 1819 Fifth Avenue North Birmingham, Alabama 35203 Telephone: (205)328-1900 Facsimile: (205)328-6000 brian.bostick@odnss.com s/ John Mark Graham John Mark Graham (LA 06216) Equal Employment Opportunity Commission 1130 22nd Street South Suite 2000 Birmingham, Alabama 35205-2881 Telephone: (205) 731-1172 Facsimile: (205) 731-1167 john.graham@eeoc.gov
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