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1 ANAND LAW, PC
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T: (626) 786-2779
10 F: (626) 380-1577
P R O F E S S I O N A L
ANAND LAW
C O R P O R A T I O N
mbaute@bautelaw.com
14 777 South Figueroa Street, Suite 4900
15 Los Angeles, California 90017
DERRICK ROSE
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22 JANE DOE (A Pseudonym),
Plaintiff,
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v.
Pursuant to FRCP 26(f), counsel for the parties, Brandon J. Anand, Esq. for
4 plaintiff JANE DOE (DOE), Mark D. Baute and Andrea Voelker for Defendant
5 DERRICK ROSE (ROSE), met telephonically on Monday, October 19, 2015, and
6 report as follows:
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9 years of age, who alleges she was raped at her apartment on Washington Boulevard
10 in Los Angeles on the morning of August 27, 2013 by all three Defendants. The
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a.
Plaintiff
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b.
Derrick Rose
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c.
Randall Hampton
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d.
Ryan Allen
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e.
Claudia Carleo
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f.
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g.
Marcella Carleo
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h.
Keyana Lavergne
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i.
Gabriela Chavez
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1 without merit.
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Insurance: None.
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4 court. Defendant intends to move to compel the plaintiff to submit to deposition, and
5 a motion for summary judgment. Plaintiff contends Defendant has submitted no
6 notice of deposition and that a summary judgment motion would never be
7 appropriate in this fact-driven case.
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Status of Discovery: At the joint status report meet and confer, held
10 on October 19, 2015, between Brandon J. Anand, for Plaintiff and Mark Baute and
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11 Andrea Voelker, for the Defendant, counsel agreed to exchange informal discovery.
12 The deadline for such exchange, per FRCP 26(a)(1)(C), is November 2, 2015. As of
13 this date, neither side has exchanged discovery. Plaintiff will depose all Defendants.
14 Defense counsel intends to depose five of the eight lay witnesses identified above,
15 along with the apartment building personnel, if any, that the Plaintiff identifies as
16 witnesses.
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Discovery Plan and Discovery Cut Off: Plaintiff suggests that lay
18 discovery can be completed by April 8, 2017. Defendant suggest that lay discovery
19 can be completed by June 1, 2016.
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Plaintiff suggests the expert discovery cut-off can be May 8, 2017. Defendant
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1 Rule 26 reports, by April 24, 2017. Defendant suggests rebuttal experts, if any, can
2 be identified, including any Rule 26 reports, by August 15, 2016.
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Plaintiff has identified one expert witness thus far, Reuben Vaisman-Tzachor.
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8 the best of the three identified alternatives. A second mediation may or may not be
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C O R P O R A T I O N
9 scheduled.
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12 Plaintiff; Mark Baute, David Crochetiere and Laura Robbins for Defendant Derrick
13 Rose. Defendants Ryan Allen and Randall Hampton have not yet been served.
14 Plaintiff has hired a process server to serve Hampton and Allen.
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18 order to avoid undue media coverage, which can detract from the merits and distract
19 the parties from resolution.
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Respectfully submitted,
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22 DATED: October 26, 2015
ANAND LAW, PC
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By:
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Joint FRCP 26(f) Report
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C O R P O R A T I O N
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Joint FRCP 26(f) Report