Joint rule 26 report

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THOMAS J. HOLMES, et. al., Plaintiffs, v.

Case No.: 14-CV-208

JOHN DICKERT, et al., Defendants.


Pursuant to this Court’s September 4, 2014 Notice of Rule 16 Scheduling Conference and Federal Rule of Civil Procedure 26(f), the parties conferred on September 12, 2014 and submit this report. At the outset, plaintiffs respectfully request that this Court revisit its directive to complete trial by October 1, 2015. See Docket #64. This case involves 22 parties and unusually complex legal issues. As this Court correctly noted, “this matter is very complex.” See Docket #60 at 2. Because of the complexity of the claims and number of parties and expected witnesses involved, plaintiffs need extensive written, electronic and oral discovery to properly investigate and prosecute their causes of action. While plaintiffs have and will continue to work diligently and efficiently to bring this matter to trial, plaintiffs also wish to be candid with this Court. In that regard, plaintiffs respectfully submit that a trial ending on October 1, 2015 will not allow plaintiffs to effectively and thoroughly engage in the discovery process and prepare for trial. Courts in this Circuit consistently note that “the scope of discovery should be broad in order to aid in the search for the truth.” See, e.g., Kodish v. Oakbrook Terrace Fire Prot. Dist., 235 FRD

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Case 2:14-cv-00208-JPS Filed 09/23/14 Page 1 of 15 Document 77