Jackson v. Birmingham, Alabama, City of et al

Filing 8

REPORT of Rule 26(f) Planning Meeting. (Fullerton, Frederic)

FILED
2012 Jan-11 AM 07:57
U.S. DISTRICT COURT
N.D. OF ALABAMA

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ALABAMA
SOUTHERN DIVISION
KAREN JACKSON,
Plaintiff,
v.
CITY OF BIRMINGHAM, et al.,
Defendants.

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CIVIL ACTION NO.
CV-11-2632-LSC

REPORT OF PARTIES PLANNING MEETING

1. Pursuant to Fed.R.Civ.P.26(f), a meeting was held via email on January
10, 2012. The meeting was attended by:
(a) For the Plaintiff: Karen Jackson, Adam P. Morel, Esq., 517
Beacon Parkway West, Birmingham, Alabama 35209; and
(b) For the Defendants: City of Birmingham and Birmingham
Library Board, Fredric L. Fullerton, II, Esq., City of Birmingham,
City Attorney’s Office 710 North 20th Street, Birmingham,
Alabama 35203.
2. Pre-Discovery Disclosures: On or before February 17, 2012, the parties
will exchange the information required by Fed.R.Civ.P. 26(a)(O) and Local
Rule 26.1(a)(1).
3. Discovery Planning: The parties jointly propose the court the following
discovery plan:
(a) Discovery will be needed on the Plaintiff’s factual allegations.
(b) All discovery will be commenced in time to be completed by July
27, 2012.
(c) A maximum of 30 interrogatories by each party. Responses to all
interrogatories will be due 30 days after service, unless extended
by agreement of the parties or order of the court.
(d) A maximum of 30 requests for production by each party to the
other party without prior approval of the court, including discreet
subparts. Responses to requests for production will be due 30 days
after service, unless extended by agreement of the parties or order
of the court.
(e) A maximum of 20 requests for admission by each party.
Responses will be due 30 days after service, unless extended by
agreement of the parties or order of the court.
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(f) A maximum of 10 depositions by Plaintiff and 10 depositions by
Defendant.
(g) No deposition shall exceed seven hours, exclusive of breaks except
for lunch, unless agreed to by the parties or ordered by the Court.
(h) Report from retained experts under Rule 26(a)(2) will be due:
From the Plaintiff by May 4, 2012;
From the Defendant by May 25, 2012.
Supplementation under Fed.R.Civ.P. 26(e) will be due 30 days before close of
discovery.
4. Other Items.
The parties DO NOT request a scheduling conference with the court before
entry of the scheduling order.
Plaintiffs should be allowed to amend the pleadings, or to join additional
parties until May 4, 2012.
Defendants should be allowed to amend the pleadings, or to join additional
parties until May 25, 2012.
All additional potentially dispositive motions shall be filed by August 31,
2012.
Settlement cannot be evaluated until some discovery is completed.
The parties request a pretrial conference 30 days prior to trial.
Final lists of trial evidence under Rule 26(a)(3) should be due:
From plaintiff: witnesses and exhibits by 30 days before trial.
From defendant: witnesses and exhibits by 30 days before trial.
The parties have 14 days after service of final list of trial evidence to list objections
under Rule 26(a)(3).
The case should be ready from trial on or after November 2012 and is
expected to take approximately 3 -5 days.

s/Adam P. Morell
Adam P. Morell
517 Beacon Parkway West
Birmingham, Alabama 35209

s/Fredric L. Fullerton, II
Fredric L. Fullerton, II
City f Birmingham Law Department
710 North 20th Street, Room 600
Birmingham, Alabama 35203

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