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)

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 [phone]
Facsimile [phone]
[e-mail]
[e-mail]

/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: [phone]
Fax: [phone]
[e-mail]
[e-mail]

Attorneys for Defendants

DANIEL MACH
AMERICAN CIVIL LIBERTIES
UNION FOUNDATION
915 15th Street NW
Washington, DC 20005
Phone: [phone]
FAX: [phone]
[e-mail]
[e-mail]
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