UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF ALABAMA

SOUTHERN DIVISION

Roger Wright, §

§

Plaintiff, §

§

v. § Civil Action No.: 1:06 cv 647-WKW

§

Pemco World Air Services, Inc. §

Defendant. §

PLAINTIFF'S REPLY TO DEFENDANT'S

RESPONSE TO MOTION TO COMPEL

Comes now the Plaintiff, Roger Wright, through counsel and for his reply and in further 

support of Plaintiff's Motion to Compel states to the Court as follows: 

1. Defendant argues that the Motion to Compel is moot on the grounds that the 

Defendant has produced some of the documents requested and has promised to provide the 

remaining discovery at an unspecified time in the future.

2. The Motion is not moot due to the fact that the Defendant has been promising to 

provide these documents to the Plaintiff for some time. Plaintiff first served Interrogatories and 

Requests for Production of Documents on the Defendant on or about January 23, 2007. The 

Defendant objected to all requested discovery and produced only those documents that they 

wanted to produce, rather than producing the documents specifically requested. 

After the Motion to Compel was filed on July 13, 2007, the Defendant provided

additional documents on July 23, 2007, July 31, 2007 and August 2, 2007. 

On July 27, 2007 counsel for Plaintiff and Defendant conferred with regard to the 

remaining discovery items and Defendant has promised to produce virtually all of the requested 

items other than with regard to the three or four documents listed in the privilege log. 

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3. The specific items still in contention as of today, August 3, 2007, are as follows:

a. The Defendant has never provided verified answers to interrogatories or response 

to discovery requests. This was promised in a letter from Defendant on February 26, 2007, but 

never received.

b. Defendant’s answers to interrogatories are insufficient as set out in Plaintiff's 

original Motion to Compel. Defendant, as of August 2, 2007, submitted revised and unverified 

answers to interrogatories. Further, Interrogatory #7 is missing addresses, age, length of service 

and job title for employees retiring in years 2001, 2002, 2003 and 2007.

c. Pertaining to document request #5, the Plaintiff had requested the Minutes of all 

Board of Directors Meetings from the years 2001 to the present. Defendant has only produced 

Board Minutes from March 2, 2004 through June 3, 2005. The Defendant indicated that further 

information would be provided, but the Plaintiff has not yet received this information.

d. With regard to document request #12, the Defendant has not produced personnel 

records of Ray Bennett and only minimal personnel records regarding Dennis Johnson and 

Henry Ward. These documents are not covered by any privilege herein and should be produced.

e. Annual Reports for the years 2001, 2002, 2003, 2006 and 2007 have not been 

produced.

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Wherefore, the Plaintiff prays that this court grant his Motion to Compel. 

Respectfully submitted,

_s/ Elizabeth B. Glasgow_____

Elizabeth B. Glasgow

ASB-8348- S58E

Attorney for Plaintiff

P.O. Box 2228

Dothan, Alabama 36302

(334) 793-2424

F. (334) 793-6624

eglasgow@fphw-law.com

CERTIFICATE OF SERVICE

I hereby certify that on August 3, 2007, I electronically filed the foregoing with the Clerk 

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

following: 

John Holmes, Esq. 

Maynard, Cooper & Gale, P.C.

1901 Sixth Avenue North, Suite 2400

Birmingham, AL 35203

__s/ Elizabeth B. Glasgow_____

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