On July 07, 2021 a
Discovery Plan Index #4
was filed
involving a dispute between
Rose, Daniel,
and
Hall, Bridgette,
for Personal Injury
in the District Court of Goodhue County.
Preview
25-CV-21-1345
Filed in District Court
aboutzblank
State of Minnesota
7/7/2021 9:47 AM
PERSONAL INJURY
STATE OF MINNESOTA DISTRICT COURT
COUNTY OF GOODHUE FIRST JUDICIAL DISTRICT
COURT FILE NO.:
Ar h Rose, a minor, by her father Judge:
an natural guardian, Daniel Rose,
Plaintiff,
Rule 26.66(c)
vs. JOINT DISCOVERY PLAN
Bridgette Hall,
Defendant.
In accordance with Rule 26.06, Minnesota Rules of Civil Procedure, counsel for the
parties conferred in person/by teiephone and have discussed the nature and basis of their claims
and defenses, the possibilities for a prompt settlement or resolution of the case, and developed a
proposed discovery plan After conferring, in person or by telephone, counsel for the parties,
agree to the following:
1. The parties have made or shall make by Rule 26.0l(a) disclosures on or before
March 5, 2021.
2. The issues on which the parties need to conduct discovery are:
Liability
Damages
Witnesses
Experts
3. The parties shall have until 240 days from date of filing to complete factual discovery
and to file dispositive/non-dispositive motions.
4. The parties shall have untii 309 days from date of liking to provide the names of expert
witnesses and complete initial expert reports under Rule 26.0} (b).
5. The parties shall have until 120 days from date of filing to move to join additional
parties.
6. The parties shall have until 180 days from date of filing to move to amend the pleadings
to add claims or defenses.
7. Counsel have discussed between themselves and explored with their clients earlyI
involvement in alternative dispute resolution. The following option(s) would be
appropriate in this case:
lof3 2/5/2021 1:12 PM
25-CV-21-1345
Filed in District Court
aboutzblank
State of Minnesota
7/7/2021 9:47 AM
a ADR Process:
_X_ Mediation
__Arbitration (non-binding)
__Arbitration (binding)
___Med-Arb
_Early Neutral Evaluation
__Moderated Settlement Conference
__Mini-Triai
__Surnmary Jury Trial
__Consensual Special Magistrate
_Impartiai Fact-Finder
_Counsel agree that ADR is appropriate but request that the Court
seiect the process.
__Counse1 agree that ADR is NOT appropriate because:
The case implicates the federal or state constitution.
Other (explain with particularity):
Domestic Violence has occurred between the parties.
b. The parties agreed to select an ADR neutral on or before 180
days from date of
fiting.
c. The parties recommend that the AER process be completed by 240 days from date
of filing.
8. The parties shall have until 270 days from date of filing for completing independent medical
examinations pursuant to Minn. R Civ. P. 35.
9. Defendant request’s trial by July.
10. The estimated length of trial is 2; days.
11. That parties agree that the case will be ready for trial on or after 1 yea r from date of filing.
Dated: January 15. 2021 /s/John Paul J. Gatto
Marcus P. Gatto, (#0391 160)
John Paul J. Gatto (#0387730)
Attorneys for Piaintiff
1177 West Seventh Street
Saint Paul, Minnesota 55102
651-454-3600
paulagazsworgattoeom
ipgx sworgattocom
20f3 2/5/2021 1:12 PM
25-CV-21-1345
Filed in District Court
aboutzblank
State of Minnesota
7/7/2021 9:47 AM
i”?
Dated Z [572/ Jefjr’ey 1
’
”3/
. qn (#40897)
\{W
f0 "Defendant
gttornq "
4’20 58 Street NW.
Rochester, MN 55901
507-282-7770
3of3 2/5/2021 1:12 PM
Document Filed Date
July 07, 2021
Case Filing Date
July 07, 2021
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25-CV-21-1345 Filed in District Court aboutzblank State of Minnesota 7/7/2021 9:47 AM PERSONAL INJURY STATE OF MINNESOTA DISTRICT COURT COUNTY OF GOODHUE FIRST JUDICIAL DISTRICT COURT FILE NO.: Ar h Rose, a minor, by her father Judge: an natural guardian, Daniel Rose, Plaintiff, Rule 26.66(c) vs. JOINT DISCOVERY PLAN Bridgette Hall, Defendant. In accordance with Rule 26.06, Minnesota Rules of Civil Procedure, counsel for the parties conferred in person/by teiephone and have discussed the nature and basis of their claims and defenses, the possibilities for a prompt settlement or resolution of the case, and developed a proposed discovery plan After conferring, in person or by telephone, counsel for the parties, agree to the following: 1. The parties have made or shall make by Rule 26.0l(a) disclosures on or before March 5, 2021. 2. The issues on which the parties need to conduct discovery are: Liability Damages Witnesses Experts 3. The parties shall have until 240 days from date of filing to complete factual discovery and to file dispositive/non-dispositive motions. 4. The parties shall have untii 309 days from date of liking to provide the names of expert witnesses and complete initial expert reports under Rule 26.0} (b). 5. The parties shall have until 120 days from date of filing to move to join additional parties. 6. The parties shall have until 180 days from date of filing to move to amend the pleadings to add claims or defenses. 7. Counsel have discussed between themselves and explored with their clients earlyI involvement in alternative dispute resolution. The following option(s) would be appropriate in this case: lof3 2/5/2021 1:12 PM 25-CV-21-1345 Filed in District Court aboutzblank State of Minnesota 7/7/2021 9:47 AM a ADR Process: _X_ Mediation __Arbitration (non-binding) __Arbitration (binding) ___Med-Arb _Early Neutral Evaluation __Moderated Settlement Conference __Mini-Triai __Surnmary Jury Trial __Consensual Special Magistrate _Impartiai Fact-Finder _Counsel agree that ADR is appropriate but request that the Court seiect the process. __Counse1 agree that ADR is NOT appropriate because: The case implicates the federal or state constitution. Other (explain with particularity): Domestic Violence has occurred between the parties. b. The parties agreed to select an ADR neutral on or before 180 days from date of fiting. c. The parties recommend that the AER process be completed by 240 days from date of filing. 8. The parties shall have until 270 days from date of filing for completing independent medical examinations pursuant to Minn. R Civ. P. 35. 9. Defendant request’s trial by July. 10. The estimated length of trial is 2; days. 11. That parties agree that the case will be ready for trial on or after 1 yea r from date of filing. Dated: January 15. 2021 /s/John Paul J. Gatto Marcus P. Gatto, (#0391 160) John Paul J. Gatto (#0387730) Attorneys for Piaintiff 1177 West Seventh Street Saint Paul, Minnesota 55102 651-454-3600 paulagazsworgattoeom ipgx sworgattocom 20f3 2/5/2021 1:12 PM 25-CV-21-1345 Filed in District Court aboutzblank State of Minnesota 7/7/2021 9:47 AM i”? Dated Z [572/ Jefjr’ey 1 ’ ”3/ . qn (#40897) \{W f0 "Defendant gttornq " 4’20 58 Street NW. Rochester, MN 55901 507-282-7770 3of3 2/5/2021 1:12 PM