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IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF ALABAMA

NORTHERN DIVISION

LEROY WILLIAMS, *

*

Plaintiff, *

*

v. * Civil Action No.:

* 2:06-cv-658-ID

STATE OF ALABAMA DEPT. OF *

TRANSPORTATION, et. al. *

Defendant. * JURY DEMAND

REPORT OF PARTIES' PLANNING MEETING

Pursuant to Fed.R.Civ.P. 26(f), a meeting was held on August 28, 2006, with

participation by the following:

RUSSELL ADAMS on behalf of plaintiff, Leroy Williams

ANDREW REDD on behalf of defendants, Alabama Department of

Transportation and Joe McInnes.

1. Pre-Discovery Disclosures. The parties will exchange by September 30,

2006 the information required by Rule 26.

2. Discovery Plan. The parties jointly propose to the court the following

discovery plan:

Discovery will be needed on the following subjects:

(a) factual information concerning the alleged discriminatory

treatment and termination of the plaintiff;

(b) any and all damages claimed by the plaintiff;

(c) plaintiff's employment history and work performance;

(d) general issues of liability; and

(e) any and all issues raised in the pleadings, including

affirmative defenses;

(f) factual information concerning the defendants’ basis for the

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plaintiff’s termination.

3. All discovery commenced in time to be completed by May 1, 2007.

4. Interrogatories: Maximum of 25 interrogatories by each party to

any other party. Responses to all Interrogatories are due 30 days after service.

5. Requests for Production: Maximum of 40 requests for production by

each party to any other party. Responses to all Requests for Production are due 30 days

after service.

6. Requests for Admission: Maximum number of 25 Requests for

Admission by each party to any other party. Response to all Requests for Admissions are

due 30 days after service.

7. Depositions: Maximum of 10 depositions by each party, each

deposition to be limited to a maximum of 7 hours unless extended by agreement of the

parties.

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

From the plaintiff by January 15, 2007

From the defendant by February 15, 2007

9. Supplementation under Rule 26. All supplementation under Rule 26

will be due immediately upon discovering additional information, with final

supplementation due within 30 days of the discovery deadline.

10. Other Items.

a. Scheduling Order Conference: The parties do not request a conference

with the court before entry of the scheduling order.

b. Additional Parties:

1. The plaintiff should be allowed until November 1, 2006 to join

additional parties and to amend the pleadings.

2. The defendant should be allowed until December 1, 2006 to join

additional parties and to add defenses and amend the pleadings.

11. All potentially dispositive motions should be filed by June 1, 2007.

12. The parties request a final pretrial conference after the close of discovery.

13. Final lists of trial evidence under Rule 26(a)(3) should be due:

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a. From the plaintiff: witnesses and exhibits by 30 days before trial;

b. From defendant: witnesses and exhibits by 30 days before trial;

c. Parties should have 14 days after service of final lists of trial

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

d. The case should be ready for trial by August 2007 and, at this

time, is expected to take approximately 2 to 3 days.

Respectfully submitted,

s/ Russell W. Adams

Russell W. Adams, ASB-3760-A62R

Attorney for Plaintiff

OF COUNSEL:

WIGGINS, CHILDS, QUINN & PANTAZIS

301 Nineteenth Street North

Birmingham, Alabama 35203

(205) 314-0500

(205) 254-1500 (facsimile)

s/ Andrew Redd

Andrew Redd, ASB-RED001

Attorney for Defendants

OF COUNSEL:

ALABAMA DEPARTMENT OF TRANSPORTATION

1409 Coliseum Boulevard

Montgomery, Alabama 36110

(334) 242-6350

(334) 264-4359 (facsimile)

electronic mail: houstons@dot.state.al.us

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