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IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF ALABAMA

SOUTHERN DIVISION

ROGER WRIGHT, )

)

Plaintiff )

)

v. ) CASE NO.: 1:06CV647-WKW

)

PEMCO WORLD AIR )

SERVICES, INC., )

)

Defendant. )

REPORT OF PARTIES’ PLANNING MEETING

1. Pursuant to Fed.R.Civ.P 26(f), a planning meeting was held on

October 4, 2006 with participation by the following:

Elizabeth B. Glasgow on behalf of Plaintiff, Roger Wright.

John B. Holmes, III on behalf of Defendant, Pemco World Air Services, Inc.

2. The synopsis of the case is as follows: Plaintiff is a male over the age

of 50 who was laid off/terminated from his position with Defendant. Plaintiff is

alleging discriminatory treatment based upon his taking a medical leave, age, and

alleged perceived disability. The claims are filed under 29 U.S.C. §2601, 29

U.S.C. § 621 and 42 U.S.C. §120101, respectively. Defendant denies Plaintiff’s

allegations.

3. Pre-Discovery Disclosures. The parties will exchange the

information required by Local Rule 26.1(a)(1) by November 1, 2006.

4. Discovery Plan. The parties jointly propose to the court the

following discovery plan:

a. Discovery will be needed on the following subjects:

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(1) the factual and legal issues and claims made by Plaintiff

in this action;

(2) any and all damages claimed by Plaintiff; and

(3) factual and legal issues related to Defendant’s defenses.

b. All discovery completed by December 14, 2007.

c. Interrogatories: Plaintiff and Defendant may each propound

up to 40 Interrogatories upon the other party. Responses to all

Interrogatories are due 30 days after service.

d. Requests for Production: Plaintiff and Defendant may each

propound 35 Requests for Production to the other party. Responses to all

requests for production are due 30 days after service.

e. Requests for Admission: Plaintiff and Defendant may

each propound 35 Requests for Admission to the other party. Responses to

all Requests for Admissions are due 30 days after service.

f. Depositions: The parties are unable to agree on the

maximum number of depositions. Counsel for Plaintiff seeks a maximum of

15 Depositions. Counsel for Defendant seeks a maximum of 8 Depositions.

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

From the plaintiff by March 30, 2007.

From the defendant by April 30, 2007.

h. Supplementation of discovery under Rule 26(e) is due within a

reasonable time. Final supplementation is due no later than 30 days prior to

the discovery deadline.

5. Other Items.

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

conference with the court before entry of a scheduling order.

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b. Additional Parties:

(1) The plaintiff should be allowed until January 31, 2007,

to join additional parties and to amend the pleadings.

(2) The defendant should be allowed until February 16,

2007, to join additional parties and to add defenses and amend the pleadings.

c. All potentially dispositive motions should be filed by

October 29, 2007.

d. Neither settlement nor the possibility for Alternative Dispute

Resolution can be realistically evaluated prior to at least some discovery.

e. The parties request a final pretrial conference on or after

December 3, 2007.

f. Final lists of trial evidence under Rule 26(a)(3) should be

submitted in accordance with the pretrial order issued by the Court.

g. The case should be ready for trial by January 2008 and, at this

time, is expected to take approximately 3-4 days.

h. ADR Plan: Mediation might assist the parties in resolving this

matter but that decision cannot be made until initial discovery is completed.

s/Elizabeth B. Glasgow s/John B. Holmes

Elizabeth B. Glasgow Jeffrey A. Lee

Harry Hall John B. Holmes, III

Farmer, Price, Hornsby & MAYNARD, COOPER & GALE, P.C.

Weatherford, L.L.P. 1901 6th Avenue North

Post Office Drawer 2228 2400 AmSouth/Harbert Plaza

Dothan, Alabama 36302 Birmingham, Alabama 35203

(334) 793-2424 (205) 254-1000

Dated this the 5

th

day of October, 2006.

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