Fill and Sign the Us District Court for the Southern District of Alabama Justia Form

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION **Plaintiff, **vs. * CIVIL ACTION NUMBER*, et al., **Defendants.** REPORT OF PARTIES PLANNING MEETING Pursuant to Fed. R. Civ. P. 26(f), a meeting was held on September 27, 1999 via telephonic conference and was attended by:________________ on behalf of Plaintiff, _________________________________ on behalf of Defendant, ____________________________________________________The Defendant ______________ has not yet been served in this action.The parties do not request a conference with the Court before entry of the scheduling order.1.Narrative Statement of the Facts and Causes of Action by Plaintiff: This is a _____ complaint brought by Plaintiff against ____________________________________________________ involving a contract (tort, etc. Now set out facts here; briefly). Narrative Statement of the Facts and Defenses by Defendant ____________________________________________ Company: (Same here; Defendant sets out their version of facts, briefly and defenses) ____________ has numerous other defenses to Mr. ________ claims, as listed in __________________ answer to Plaintiff s complaint. 2. Trial. This jury action should be ready for trial by October 2000 or later according to the determination of dispositive motions, and at this time is expected to take approximately two to three days. -2- 3. Pretrial Conference: The parties request a final pretrial conference in September 2000, or 30 days before trial. 4.Discovery Plan: The parties jointly propose to the Court the following Discovery Plan: Plaintiff and Defendant propose discovery on the issues raised in Plaintiffs Complaint and in Defendant s Answer. Plaintiff particularly seeks discovery on issues including how the policy purchased by the Plaintiff works; the practices and customs of ____________________________________________ Company; the Defendants policies regarding Alabama Department of Insurance Regulations; and the pattern and practice of fraudulent conduct alleged by the Plaintiff. Defendant particularly seeks discovery on the Plaintiff s claims and the Plaintiff s sophistication and background.All discovery shall be commenced in time to be completed by July 31, 2000.5. Initial Disclosures: The parties will exchange by October 17, 1999, the information required by Fed. R. Civ. P. 26(a)(1). 6.Joinder of Parties : The parties request until January 31, 2000, for the Plaintiff to join additional parties and amend the pleadings, and until February 28, 2000, for the Defendant to join additional parties. 7. Expert Witnesses: Parties have agreed to exchange summaries of expert qualifications and opinions and to submit all materials discoverable relative to their experts rather than prepare formal expert reports required under Fed. R. Civ. P. 26(a)(2). Plaintiff shall submit its expert summary by May 31, 2000, and Defendant shall submit its expert summary by June 30, 2000. Plaintiff shall make its expert(s) available for deposition, following which Defendant shall make its expert(s) available for deposition, all within the discovery period. 8.Pretrial Disclosures: Final lists of witnesses and exhibits under Rule 26(a)(3) shall be due: from Plaintiff: 30 days prior to trial;from Defendant: 20 days prior to trial;parties shall have 10 days after service of final lists of trial evidence to file objections under Rule 26(a)(3).9.Discovery Limits: Parties were unable to reach an agreement on discovery limits. Plaintiff seeks: Maximum of 80 interrogatories (including subparts) by each party to any other party. Responses due 30 days after service.Maximum of 10 depositions by Plaintiff and 10 by Defendant. Each -3- deposition is not limited to a maximum of hours.Maximum of 40 requests for admissions by each party to any other party. Responses are due 30 days after service.Maximum of 80 requests for production of documents by each party to any other party. Responses due 30 days after service.Defendant seeks to limit discovery to: Maximum of 60 interrogatories (including subparts) by each party to any other party. Responses due 30 days after service.Maximum of 5 depositions by Plaintiff and 5 by Defendant. Each deposition is not limited to a maximum of hours.Maximum of 30 requests for admissions by each party to any other party. Responses are due 30 days after service.Maximum of 50 requests for production of documents by each party to any other party. Responses due 30 days after service.10.Dispositive Motions: All potentially dispositive motions filed by August 31, 2000. 11.Settlement. Settlement cannot be evaluated prior to discovery cut-off, and may be enhanced by mediation. Date: __________________, 1999.______________________________________Plaintiff s attorney and federal number_________________& ASSOCIATES, P.C.Attorneys for Plaintiff, _______________Post Office Drawer ____Mobile, Alabama _____(334) ______________________________________________Attorney for Defendant and federal number______________________Attorneys for Defendant_________________________________AddressPhone (205) 254-1000 -4-