IN THE DISTRICT COURT OF THE UNITED STATES FOR THE 

MIDDLE DISTRICT OF ALABAMA, EASTERN DIVISION 

GREAT SOUTHERN WOOD * 

PRESERVING, INC., * 

* 

Plaintiff, * 

* 

v. * CIVIL ACTION NO _1:06 CV 708__ 

* 

AMERICAN HOME ASSURANCE * 

COMPANY; AIG; AMERICAN * 

INTERNATIONAL UNDERWRITERS * 

CORPORATION; AMERICAN * 

INTERNATIONAL MARINE AGENCY * 

* 

* 

Defendants * 

REPORT OF PARTIES PLANNING MEETING

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

regarding proposed deadlines in this case and submit the following joint report: 

Blane Crutchfield for Defendant; 

Kenneth A. Dowdy. for Plaintiff; and 

Leslie A. Caldwell for Plaintiff. 

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

required by Fed. R. Civ. P. 26(a)(1), within 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 all issues raised by the pleadings including : 

(a) Plaintiff’s right to coverage under the policy; (b) the basis for denial of coverage and 

(c) Plaintiff’s damages, if any. 

All discovery commenced in time to be completed by June 30, 2007. 

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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 admissions by each party to any other party. 

Responses due 30 days after service. 

Maximum of 10 depositions by Plaintiff and 10 depositions by Defendants. 

Each deposition limited to maximum of 7 hours, unless extended by agreement of 

the parties. 

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

due from Plaintiff by March 30, 2007 and from Defendants by April 7, 2007. Rebuttal 

expert reports are due 14 days after receipt of the opposing expert report. 

Supplementations are 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 conference with the Court 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 ninety (90) days of the entry of the Court’s Scheduling Order. 

All potentially dispositive motions should be filed no later than May 30, 2007. 

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It is unknown at this time whether settlement may be enhanced by the use of 

mediation. 

The parties request a pretrial hearing in August 2007. 

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

be due thirty (30) days prior to trial. 

The parties shall have ten (10) days after service of final lists of witnesses, 

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

The case should be ready for trial in September, 2007, and at this time is expected 

to take approximately 3 days to try. 

Respectfully submitted this 10th day of October, 2006. 

/s/ Kenneth A. Dowdy 

KENNETH A. DOWDY (DOW015) 

LESLIE A. CALDWELL (CAL047). 

Attorneys for Plaintiff Great Southern Wood 

Preserving, Inc. 

Lusk Lusk Dowdy & Caldwell, P.C. 

2101 Highland Avenue 

Suite 410 

Birmingham, AL 35205 

(205) 933-7090 

(205) 933-7099 (fax) 

/s/ Blane H. Crutchfield 

 ROGER L. BATES (BATER8176) 

 BLANE H. CRUTCHFIELD (CRUTB4243) 

Attorneys for Defendant American Home 

Assurance Company 

HAND ARENDALL, L.L.C. 

P.O. Box 123 

Mobile, AL 36601-0123 

(251) 432-5511 

(251) 694-6375 

539959_1 

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