IN THE UNITED STATES DISTRICT COURT 

FOR THE MIDDLE DISTRICT OF ALABAMA 

EASTERN DIVISION 

LUMBERMAN’S UNDERWRITING * 

ALLIANCE and CAMBRIDGE * 

INTEGRATED SERVICES GROUP, INC. * 

as Subrogees of TRANSPORT LEASING/ * 

CONTRACT, INC.; HANSEN & ADKINS * 

AUTO TRANSPORT, * 

 * 

 Plaintiffs, * 

 * 

vs. * Civil Action No.3:06-CV-645-MEF 

 * 

EMORY LEE YOUNG * Formerly Russell County Circuit

an individual, * Court Case No: CV-06-224 

 * 

 Defendants. * 

JOINT MOTION TO EXTEND CERTAIN DEADLINES

AND AMEND SCHEDULING ORDER

 COMES NOW the defendant, Emory Lee Young, with the consent of the plaintiffs, and 

respectfully moves this Court to extend certain deadlines and amend the scheduling order in this 

case. As grounds therefor, the defendant states as follows: 

1. This Court’s scheduling order set the following dates and deadlines: 

a. Discovery cutoff: February 9, 2007; 

b. Deadline for dispositive motions and plaintiffs’ deadline to disclose 

experts: February 23, 2007; 

c. Face-to-face settlement conference and defendant’s deadline to disclose 

experts: March 23, 2007; 

d. Exchange witness and exhibit lists, discovery for use at trial: May 16, 

2007; 

e. Pretrial conference: May 24, 2007; 

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f. Trial: June 25, 2007. 

 2. The parties have worked diligently in discovery to date. Numerous subpoenas 

have been issued and documents have been received in response to the same. This defendant has 

served interrogatories and requests for production to the plaintiffs. The deposition of the 

investigating Alabama State Trooper is set for next week, January 24, 2007 in Dothan. The 

depositions on James John (the injured employee for whose injuries and benefits the plaintiffs 

seek subrogation) and other fact witnesses are currently being arranged. 

 3. Despite the best efforts of the undersigned counsel and counsel for the plaintiffs, 

it appears impossible to complete discovery by the current discovery cutoff date. The parties 

jointly propose that the scheduling order be amended as follows to allow ample time to complete 

discovery while keeping time for dispositive motions to be filed and answered well in advance of 

the pretrial conference: 

 a. Discovery cutoff: March 16, 2007; 

 b. Deadline for dispositive motions and plaintiffs’ deadline to disclose 

experts: April 6, 2007; 

 c. Responses to any dispositive motions due within 4 weeks of service of the 

dispositive motion (latest possible date: May 4, 2007); 

 d. Reply briefs for any dispositive motions due within 1 week of service of 

the response to the dispositive motion (latest possible date: May 11, 2007); 

 e. Face-to-face settlement conference and defendant’s deadline to disclose 

experts: May 18, 2007; 

 f. Pretrial conference: remain on May 24, 2007; 

 g. Trial: remain on June 25, 2007. 

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 4. Counsel for the plaintiffs have indicated they plan to move the Court to extend the 

deadline to amend, so as to name a new defendant, namely Louis Berry. The undersigned does 

not object to this amendment. If the Court allows such an amendment, and the dates provided 

above become unworkable, the undersigned requests this Court to enter a new scheduling order 

in light of any such amendment. 

 WHEREFORE, PREMISES CONSIDERED, the parties respectfully request that this 

Court extend those certain deadlines set forth above and amend the scheduling order in this case, 

as outlined above. 

 Respectfully Submitted, 

 

 

 /s/ Joshua J. Jackson_________________ 

 Joshua J. Jackson (JAC072) 

OF COUNSEL: 

SAMFORD & DENSON, LLP

P. O. Box 2345 

Opelika, Alabama 36803-2345 

Phone: (334) 745-3504 

Facsimile: (334) 745-3506 

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CERTIFICATE OF SERVICE

 I hereby certify that on January 19, 2007 I electronically filed the foregoing with the 

Clerk of Court using the CM/ECF system which will send notification of such filing to the 

following: 

Michael S. Jackson 

Ryan Wesley Shaw 

Beers, Anderson, Jackson, Patty & Van Heest, P.C. 

P.O. Box 1988 

Montgomery, AL 36102-1988 

 

 /s/ Joshua J. Jackson______________ 

 OF COUNSEL 

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