IN THE UNITED STATES DISTRICT COURT 

FOR THE MIDDLE DISTRICT OF ALABAMA 

EASTERN DIVISION 

SANDI PHILLIPS AND RONALD J. ) 

PHILLIPS, ) 

 ) 

) 

Plaintiffs, ) CIVIL ACTION NO. 

 ) 

) 3:06-CV-00744-SRW 

v. ) 

 ) 

) 

ST. PAUL TRAVELERS INSURANCE ) 

COMPANY, ) 

 ) 

Defendant. ) 

REPORT OF PARTIES PLANNING MEETING

1. Pursuant to Fed. R. Civ. P, 26 (f), a meeting was held on October 27, 2006 

and was attended by: 

Josh McKoon for Plaintiffs Sandi Phillips and Ronald J. Phillips 

Brenen G. Ely for defendant Travelers Insurance Company, improperly 

referred to as “St. Paul Travelers Insurance Company” in the complaint. 

2. Pre-Discovery Disclosures. The parties will exchange by November 22, 2006, 

information required by Federal Rule of Civil Procedure 26 (a)(1). 

3 Discovery Plan. 

The parties jointly propose to the Court the following discovery plan: 

Discovery will be needed on the following subjects: Plaintiff’s claims and 

Defendant’s defenses. 

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

Maximum of 40 interrogatories by each party to any other party. 

[Responses due 30 days after service.] 

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Maximum of 40 requests for admissions by each party to any other party. 

[Responses due 30 days after service]. 

Maximum of 7 depositions by Plaintiff and 7 depositions by Defendant. 

Each deposition limited to a maximum of 7 hours unless extended by 

agreement of the parties. 

Reports from retained experts due: 

From Plaintiff by March 6, 2007 

From Defendant by April 6, 2007 

Supplementations under Rule 26(e) due April 1, 2007. 

4. Other Items. 

The parties do not request a conference with the Court before the entry of the 

Scheduling Order. 

The parties request a pre-trial conference in August 2007. 

Plaintiffs should b allowed until January 6, 2007 to join additional parties and 

until January 6, 2007 to amend the pleadings. 

Defendant should b allowed until February 6, 2007 to join additional parties 

and until February 6, 2007 to amend the pleadings. 

All potentially dispositive motions should b filed by May 8, 2007. 

Settlement cannot be evaluated prior to the parties conducting some discovery 

and may, at a later date, be enhanced by use of mediation. 

Final lists of witnesses and exhibits under Rule 26(a)(3) should be due: 

From Plaintiffs: 30 days before trial. 

From Defendants: 30 days before trial. 

Parties should have 14 days after service of final lists of witnesses and 

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

The case should be ready for trial by August 2007 and at this time is expected 

to take approximately 3-4 days. 

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Case 3:06-cv-00744-SRW Document 6 Filed 10/27/2006 Page 2 of 3
Submitted this 27th day of October, 2006. 

ATTORNEY FOR PLAINTIFF: ATTORNEY FOR DEFENDANT: 

/s/ Joshua R. McKoon /s/ Brenen G. Ely 

________________________ __________________________ 

Joshua R. McKoon Brenen G. Ely 

McKoon & Thomas Ely & Isenberg, LLC 

P.O. Box 3220 600 Beacon Parkway West 

Phenix City, AL 36868-3220 Suite 104 

(334) 297-2300 Birmingham, AL 35209 

(334) 297-2777 (FAX) (205) 313-1200 

 (205) 313-1201 (FAX) 

 

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