IN THE UNITED STATES DISTRICT COURT FOR THE

MIDDLE DISTRICT OF ALABAMA

NORTHERN DIVISION

Grady Clifford Smith,

Plaintiff,

vs. Civil Action No.:

Hyundai Motor Manufacturing 2:06-cv-745-WKW-CSC

Alabama, LLC,

Defendant.

_____________________________

REPORT OF PARTIES’ RULE 26 PLANNING MEETING

Pursuant to Fed R. Civ. P. 26(f), the parties discussed and agreed to the following schedule for

discovery and trial:

1. Pre-Discovery Disclosures. Defendant proposesthat the parties will exchange within 30

days of the meeting the information required by Rule 26.

2. Discovery Plan. Defendant proposes the following discovery plan:

a. Discovery will be needed on Plaintiff’s claims and Defendant’s

defenses.

b. All discovery commenced in time to be completed by July 31,

2007.

c. The parties request a maximum of 25 interrogatories by each

party to any other party.

Responses due 30 days after service.

d. The parties request a maximum of 25 Requests for Production.

Responses due 30 days after service.

Case 2:06-cv-00745-WKW-CSC Document 6 Filed 10/03/2006 Page 1 of 3
e. The parties request a maximum of 15 Requests for

Admission.

Responses due 30 days after service.

f. The parties request a maximum of 8 depositions by each party.

g. Each deposition limited to maximum of 7 hours unless extended

by agreement of parties.

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

Plaintiff by April 15, 2007; from Defendant by May 15, 2007.

i. Supplementation under Rule 26(e) due 30 days after receipt

of information and last supplementation 30 days before the

close of discovery.

3. Other items. The parties do not request a conference with the

Court before entry of the Scheduling Order.

a. The parties request a pretrial conference in October 2007.

b. The Plaintiff should be allowed until January 15, 2007, to

join additional parties and amend the pleadings.

The Defendantshould be allowed until February 15, 2007, to join

additional parties and amend the pleadings.

c. All potentially dispositive motions should be filed by

July 15, 2007.

d. Settlement cannot be evaluated prior to the commencement of

discovery.

e. Final lists of witnesses and exhibits under Rule 26(a)(3) should

be due three weeks before trial.

f. Parties should have 10 days after service of final lists of

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

g. The case should be ready for trial by the scheduled trial term

beginning December 10, 2007, in Montgomery, Alabama and at

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this time is expected to take approximately three days.

DATED this 3rd day of October, 2006.

THIS WILL CERTIFY THAT ALL PARTIES HAVE AGREED TO THE ABOVE AND HAVE

AGREED THAT SANDRA B. REISS WILL E-FILE THE FOREGOING REPORT OF PARTIES'

PLANNING MEETING. SPECIFICALLY, THE ABOVE IS AGREED TO BY:

FOR PLAINTIFF FOR DEFENDANT

/s/Cynthia Wilkinson(with permission) /s/Sandra B. Reiss

Cynthia Forman Wilkinson J. Trent Scofield (ASB-1191-e67j)

Wilkinson Law Firm, PC Sandra B. Reiss (ASB-3650-s80s)

215 Richard Arrington Jr. Blvd. N. Ogletree, Deakins, Nash, Smoak & Stewart,

Suite 811 One Federal Place

Birmingham, AL 35203 Suite 1000

(205) 250-7866 1819 Fifth Avenue North

Birmingham, AL 35203

e-mail: Trent.Scofield@odnss.com

e-mail: Sandra.reiss@odnss.com

Ph. (205) 328-1900

Fax: (205) 328-6000

/s/Scott Harwell (with permission)

Scott Harwell

P. O. Box 380966

Birmingham, AL 35238

Ph. 980-1445

Case 2:06-cv-00745-WKW-CSC Document 6 Filed 10/03/2006 Page 3 of 3