Roehm v. Wal-Mart Stores, Incorporated

Filing 7

Roehm v. Wal-Mart Stores, Incorporated

Doc. 7

Case 2:07-cv-10168-LPZ-RSW

Document 7

Filed 02/23/2007

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UNITED STATES DISTRICT COURT IN THE EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION Julie Ann Roehm, Plaintiff, v. Wal-Mart Stores, Inc., Defendant. John F. Schaefer (P19948) B. Andrew Rifkin (P46147) The Law Firm of John F. Schaefer Attorneys for Plaintiff 380 N. Old Woodward, Suite 320 Birmingham, MI 48009 [phone] [e-mail] Debra M. McCulloch (P31995) DYKEMA GOSSETT, PLLC Attorneys for Defendant 39577 Woodward Avenue, Suite 300 Bloomfield Hills, MI 48304 [phone] [e-mail] Eugene Scalia Karl G. Nelson David J. Debold (P39278) Gibson, Dunn & Crutcher LLP Of Counsel for Defendant 1050 Connecticut Avenue, N.W. Washington D.C. 20036 [phone] [e-mail] / REPORT OF RULE 26(f) CONFERENCE AND DISCOVERY PLAN 1. Pursuant to Fed. R. Civ. P. 26(f), a meeting was held on February 5, 2007 at the CASE NO.: 2:07-cv-10168 Honorable Zatkoff, Lawrence P. Referral Judge: Whalen, R. Steven

offices of The Law Firm of John Schaefer and was attended by: John Schaefer and B. Andrew Rifkin for Plaintiff Julie Roehm Debra McCulloch and Karl Nelson (via telephone conference) for Defendant Wal-Mart, Stores, Inc.

Dockets.Justia.com

Case 2:07-cv-10168-LPZ-RSW

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Filed 02/23/2007

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2.

Pre-Discovery Disclosures. The parties will exchange by March 2, 2007 the

information required by Fed. R. Civ. P. 26(a)(1). The parties do not require any other changes to the timing, form or requirements for disclosures under Rule 26(a). 3. plan: Discovery will be needed on the following subjects: liability, defenses and damages. The parties have agreed to the following initial provisions regarding the discovery of electronically stored information: (i) the relevant time frame for purposes of discovery involving electronically stored information will be January 1, 2006 through the present; and (ii) sources of potentially discoverable electronically stored information may include information that is readily accessible on computers or hard drives. The parties have agreed to an order regarding claims of privilege or protection as trial preparation material asserted after production in the form of Exhibit A. All discovery will be commenced in time to be completed by August 1, 2007. Interrogatories and Requests for Production of Documents will be served by no later than May 15, 2007. Motions to compel with respect to written discovery will be filed by the earlier of June 30, 2007 or the 30th day following receipt of the discovery response to which the motion is directed. The parties have agreed that no changes are needed to the limitations imposed by the court rules on the number of interrogatories or depositions that may be taken. The parties have agreed that reports from retained experts under Rule 26(a)(2) are due as follows: Discovery Plan. The parties jointly propose to the Court the following discovery

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From Plaintiff's expert(s): 90 days before trial date. From Defendant's expert(s): 30 days after the disclosure of Plaintiff's experts. 4. Other Orders. The parties request that the following be entered by the Court as a Scheduling Order: The parties will exchange witness list and expert witness disclosures no later than July 1, 2007 The parties will complete all discovery by August 1, 2007 Any amendments to the pleadings (including addition of new parties) must be filed by April 15, 2007. Summary judgment motions must be filed by September 15, 2007. 5. Settlement: The parties discussed prospects for possible settlement during the Rule 26(f) conference. Plaintiff's counsel subsequently provided Defendant's counsel with a written settlement demand, which Defendant is evaluating.

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Respectfully Submitted, s/with consent John F. Schaefer John F. Schaefer (P19948) B.Andrew Rifkin (P46147) The Law Firm of John F. Schaefer Attorneys for Plaintiff 380 N. Old Woodward, Suite 320 Birmingham, MI 48009 [phone] [e-mail] s/Debra M. McCulloch s/Debra M. McCulloch (P31955) Debra M. McCulloch (P31995) Dykema Gossett PLLC Attorneys for Defendant 39577 Woodward Avenue, Suite 300 Bloomfield Hills, MI 48304 [phone] [e-mail] s/with consent of Eugene Scalia_____ Eugene Scalia Karl G. Nelson David J. Debold (P39278) Gibson, Dunn & Crutcher LLP Of Counsel for Defendant 1050 Connecticut Avenue, N.W. Washington, D.C. 20036 [phone] [e-mail] Date: February 23, 2007

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CERTIFICATE OF SERVICE I hereby certify that on February 23, 2007, I electronically filed the foregoing paper with the Clerk of the Court using the ECF system which will send notification of such filing to the following: John F. Schaefer (P19948) at [e-mail] and B. Andrew Rifkin (P46147) at [e-mail] and to Eugene Scalia at [e-mail]. s/Debra M. McCulloch Dykema Gossett PLLC 39577 Woodward Avenue, Suite 300 Bloomfield Hills, MI 48304-5086 [phone] E-mail: [e-mail] P31995

BH01\706831.2 ID\DMM

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