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IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF ALABAMA

EASTERN DIVISION

Keith Lawson, )

)

Plaintiff, )

)

v. ) CASE NO. 3:06-cv-641-WKW

)

City of Alexander City, )

Mayor Barbara H. Young and )

Danny Peppers, in the individual )

capacities, )

)

Defendants. )

REPORT OF PARTIES’ PLANNING MEETING

1. Pursuant to Fed.R.Civ.P.26(f), the following attorneys conferred on or

about September 21, 2006.

Jon C. Goldfarb, Esq. and Maury S. Weiner, Esq., counsel for Plaintiff.

Randall Morgan, counsel for Defendants City of Alexander City, Mayor

Barbara H. Young and Danny Peppers.

2. Pre-Discovery Disclosures. The Parties will exchange the information

required by Fed.R.Civ.P.26(a)(1) by October 16, 2006.

3. Discovery Plan. Discovery will be required on the allegations made in

Plaintiff’s complaint and the defenses raised in Defendant’s answer. The parties

jointly propose to the court the following discovery plan:

a. All discovery commenced in time to be completed by the pre-trial

conference;

b. A total of 40 Interrogatories and 40 Requests for Production by

the Plaintiff and by each Defendant to any other party.

Responses due thirty (30) days after service.

c. A total of 30 Requests for Admission by the Plaintiff and by each

Defendant to any other party. Responses due thirty (30) days

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after service.

d. The parties have agreed to limit depositions to a total of ten (10)

on behalf of either party except by agreement of the parties or for

good cause.

e. Each deposition, except for Plaintiff, Defendants Young, Peppers

and representative of the City of Alexander City, and experts shall

be limited to a maximum of 6 hours unless extended by

agreement of parties,

f. Reports from retained experts under Rule 26(a)(2) due:

From Plaintiff by May 1, 2007.

From Defendant by June 1, 2007.

g. The parties agree to supplement discovery pursuant to Rule

26(e).

4. Other items.

a. The parties do not request a conference with the court before

entry of the Scheduling Order. To the extent the Court prefers to

hold such a conference, the parties respectfully request that it be

handled telephonically.

b. The parties request a pre-trial conference in October, 2007.

c. Plaintiff should be allowed until February 15, 2007, to join

additional parties and until February 15, 2007, to amend

pleadings.

d. Defendant should be allowed until March 15, 2007, to join

additional parties and until March 15, 2007, to amend pleadings.

e. All potentially dispositive motions should be filed ninety days

before pre-trial conference.

f. As this matter has only recently been filed, settlement cannot be

evaluated at this time, although the parties are hopeful that they

will be able to reach an amicable resolution of this matter and will

negotiate in good faith in this regard.

g. Final lists of witnesses under Rule 26(a)(3) should be due: 

From Plaintiff by twenty-one (21) days before pre-trial conference.

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From Defendant by twenty-one (21) days before pre-trial

conference.

h. Final lists of exhibits under Rule 26(a)(3) should be due twentyone (21) days before trial date.

I. Parties shall have fourteen (14) days after service of final lists of

witnesses to list objections under Rule 26(a)(3). 

j. Parties shall have fourteen (14) days after service of exhibit lists

to file objections.

The case should be ready for trial by December 10, 2007, and at this time is

expected to take approximately two days.

 /s/ John C. Goldfarb 

JON C. GOLDFARB (GOL015)

Attorney for Plaintiff Keith Lawson

OF COUNSEL:

Wiggins, Childs, Quinn & Pantazis, P.C.

The Kress Building

301 19th Street North

Birmingham, Alabama 35203

 /s/ Randall Morgan 

RANDALL MORGAN (MOR037)

Attorney for Defendants City of 

Alexander City, Mayor Barbara Young

and Danny Peppers

OF COUNSEL:

HILL, HILL, CARTER, FRANCO

 COLE & BLACK, P.C.

P. O. Box 116

Montgomery, AL 36101

(334) 834-7600

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