Hunter v. Salem, Missouri, City of et al

Filing 29

JOINT SCHEDULING PLAN by Defendants Board of Trustees, Salem Public Library, Glenda Woffard, Plaintiff Anaka Hunter.. (Doty, Grant)

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IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION ANAKA HUNTER, ) ) ) ) ) No. 4:12-cv-004 ERW ) ) ) ) ) Plaintiff, v. BOARD OF TRUSTEES, SALEM PUBLIC LIBRARY, et al., Defendants. JOINT PROPOSED SCHEDULING PLAN COME NOW the parties, by and through their attorneys, and respectfully submit a Joint Proposed Scheduling Plan pursuant to this Court’s Order of April 11, 2012 (Doc. # 28): I. Scheduling Plan: 1. This case has been appropriately assigned to Track 2 (Standard). 2. All motions for joinder of additional parties or amendment of the pleadings should be filed no later than July 6, 2012. 3. Discovery shall proceed in the following manner: (a) The parties shall make all disclosures required by Rule 26(a)(1), FED.R.CIV.P., no later than May 15, 2012. (b) Discovery shall not be conducted in phases or limited to certain issues. (c) Any party that plans to offer expert testimony shall disclose all expert witnesses and shall provide the reports required by Rule 26(a)(2), Fed.R.Civ.P., no later than 1 August 31, 2012, and shall make expert witnesses expected to testify at trial available for depositions no later than September 14, 2012. (2) Any rebuttal experts shall be disclosed and shall provide the reports required by Rule 26(a)(2), Fed.R.Civ.P., no later than October 5, 2012, and be made available for depositions no later than October 19, 2012. (c) The presumptive limit of twenty-five (25) interrogatories per party as set forth in Rule 33(a), Fed.R.Civ.P., shall apply. The presumptive limit of ten (10) depositions per side as set forth in Rule 30(a)(2)(A), Fed.R.Civ.P., shall apply. (d) Motions for physical or mental examinations of the parties will not be made. (e) The parties shall complete all discovery in this case no later than November 16, 2012. 4. The parties believe that referral of this action to Alternative Dispute Resolution would be appropriate. 5. Any dispositive motion or, if necessary, motion to exclude testimony pursuant to Daubert v. Merrell Dow Pharmaceuticals Inc. or Kuhmo Tire Co. Ltd v. Carmichael must be filed no later than January 11, 2013. 2 II. Trial. The parties submit that this case will be ready for a bench trial on or after June 24, 2013. It is anticipated that the length of time to try the case to verdict is approximately three days. Respectfully submitted, /s/Matt Cologna M. DOUGLAS HARPOOL #28702 MATT COLOGNA, #62020 BAIRD, LIGHTNER, MILLSAP & HARPOOL, P.C. 1901-C South Ventura Avenue Springfield, MO 65804-2700 Telephone (417) 887-0133 Facsimile (417) 887-8740 /s/ Grant R. Doty ANTHONY E. ROTHERT, #44827MO GRANT R. DOTY, #60788MO AMERICAN CIVIL LIBERTIES UNIONOF EASTERN MISSOURI 454 Whittier Street St. Louis, Missouri 63108 Phone: 314/652-3114 Fax: 314/652- 3112 Attorneys for Defendants DANIEL MACH AMERICAN CIVIL LIBERTIES UNION FOUNDATION 915 15th Street NW Washington, DC 20005 Phone: (202) 675-2330 FAX: (202) 546-0738 Attorneys for Plaintiff 3 CERTIFICATE OF SERVICE I hereby certify that on April 24, 2012, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system and a copy was made available electronically to all electronic filing participants. /s/ Grant R. Doty 4

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