IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF ALABAMA

EASTERN DIVISION

BARBARA JEFFERS and, )

JOAN CRAIG, )

Plaintiffs, )

Vs. ) Case No. 3:06cv685-WKW

RUSSELL COUNTY BOARD OF )

EDUCATION et al., )

Defendants. )

AMENDED REPORT OF PARTIES PLANNING MEETING

1. Pursuant to Court’s Order of June 5, 2007 and pursuant to Fed. R. Civ. P. 26(f),

the following attorneys have conferred regarding proposed deadlines in this case and submit the

following amended joint report:

W. Don Eddins for plaintiff;

Sydney S. Smith for defendant Russell County Board of Education;

Matthew C. Williams for defendant Charles Nacrelli.

2. Pre-Discovery Disclosures. The parties will exchange the information required

by Fed. R. Civ. P. 26(a)(1), within twenty-one (21) days of the entry of the Court’s Scheduling

Order.

3. Discovery Plan. The parties jointly propose to the court the following discovery

plan: Discovery will be needed on the following subjects: (a) plaintiffs’ claims that they were

sexually harassed and battered by supervisor Nacrelli on their jobs with the Russell County

Board of Education; (a) defendant Russell County Board of Education’s denial that certain events

occurred and/or that such events were properly reported; and (c) defendant Nacrelli’s denial that

he harassed or battered plaintiffs.

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

Maximum of 30 interrogatories by each party to any other party. Responses due 30 days

after service.

Maximum of 30 requests for production by each party to any other party. Responses due

30 days after service.

Maximum of 30 requests for admission by each party to any other party. Responses due

30 days after service.

Maximum of 10 depositions by plaintiff and 10 by defendants.

Each deposition limited to maximum of 8 hours, unless extended by agreement of the

parties.

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To the extent applicable, reports from retained experts under Rule 26(a)(2) due from the

plaintiff by August 1, 2007, and from the defendants by September 1, 2007.

Supplementations due within 14 days after any party learns that in some material respect

the information disclosed is incomplete or incorrect and if the additional or corrective

information has not otherwise been made known to other parties in the discovery process or in

writing.

4. Other Items.

The parties are of the opinion that a conference with the Court, unless the Court would

prefer to have such a conference in chambers, by telephone, or otherwise will not be needed prior

to the entry of the Scheduling Order.

Any motions to amend the pleadings or to join additional parties should be filed within

seventy-five (75) days of the entry of the Court’s Scheduling Order.

All potentially dispositive motions should be filed no later than ninety (90) days prior to

the pretrial hearing.

Settlement may be enhanced by the use of mediation after discovery is completed.

The parties request a pretrial hearing in February 2008.

Final lists of witnesses, exhibits, and deposition excerpts under Rule 26(a)(3) shall be due

from the plaintiff and the defendants thirty (30) days prior to trial.

The parties should have ten (10) days after service of final lists of witnesses, exhibits, and

deposition excerpts to make objections under Rule 26(a)(3).

Requested voir dire questions, proposed jury instructions, and motions in limine (fully

briefed) shall be filed fourteen (14) days prior to trial.

The case should be ready for trial for the March 10, 2008 term in Opelika, Alabama, and

at this time is expected to take approximately two days to try.

Respectfully submitted this 11th day of June, 2007.

/s/

W. Don Eddins (EDD005)

Attorney for Plaintiff

337 E. Magnolia Avenue, Ste. 3

Auburn, AL 36830

(334) 821-9981

Facsimile (334) 826-7700

Email: doneddins@charter.net

Case 3:06-cv-00685-WKW-CSC Document 17 Filed 06/14/2007 Page 2 of 3
CERTIFICATE OF SERVICE

I hereby certify that on 11th day ofJune, 2007, I have electronically filed the foregoing

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

the following:

Sydney S. Smith, Esq. Matthew C. Williams, Esq.

Smith and Smith Estes, Sanders & Williams, LLC

1503 Broad Street 3800 Colonnade Parkway, Ste. 330

Phenix City, AL 36830 Birmingham, AL 35243

/s/W. Don Eddins (ASB-1424-S65W)

Attorney for Plaintiff

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