Federal Document 72 - Case No. 13-CV-1624-W-NLS
JOINT CASE MANAGEMENT STATEMENT AND RULE 26(f) REPORT
Highlights:
4. MOTIONS
b. Anticipated Motions
Plaintiffs will be filing a motion to dismiss the Complaint and proceed solely on the complaint filed in state court. If this Court does not grant Plaintiffs anticipated motion to dismiss this case, all parties anticipate they will likely file motions in limine. Defendants anticipate that they will likely seek summary judgment or partial summary judgment.

8. DISCOVERY
f. Discovery Taken To Date
The following discovery has been taken in the state-court action. (See Section 10 below)
i. Depositions
Angela Tsuida on December 16, 2014
Hank Lebitski on December 17, 2014
Todd Norton on December 18, 2014
Kim James on January 20, 2015
Adam Shacknai on January 30, 2015
Susan Budinger on January 27, 2015
Howard Loehner on January 22, 2015
Xena Zahau on January 22, 2015
Mary Zahau-Loehner on January 23, 2015
Mitch McKay on March 23, 2015
Bob Kline on March 24, 2015
Thomas Adkins on March 25, 2015
Van Erhard on March 26, 2015
Keith James on April 1, 2015
Angel Cedeno on April 2, 2015
Troy Dugal on April 14, 2015
Dave Hillen on April 15, 2015
Brian Patterson on April 16, 2015
Mike Palmer on April 17, 2015
Mike Maccecca on April 20, 2015
Brande Silverthorn on June 16, 2015
Linda Wright on June 16, 2015
Denys Williams on June 17, 2015
Harres Karim on June 18, 2015
12. SETTLEMENT AND MEDIATION
The parties initially discussed settlement in their Early Neutral Evaluation Conference held on December 9, 2014 and did not reach settlement. The parties have come to the conclusion that no ADR process is likely to deliver benefits sufficient to justify the resources committed to its use, and this case should be exempted from participating in any ADR process.
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