G R E E N B E R G G L U S K E R F I E L D S C L A M A N & M A C H T I N G E R L L P
1 9 0 0 A v e n u e o f t h e S t a r s , 2 1 s t F l o o r L o s A n g e l e s , C a l i f o r n i a 9 0 0 6 7 - 4 5 9 0
2JOINT RULE 26(f) REPORT
Plaintiff Tom Cruise (“Plaintiff”) and Defendants Bauer PublishingCompany, L.P., Bauer Magazine L.P., Bauer Media Group, Inc., Bauer, Inc., andHeinrich Bauer North America, Inc. (collectively, “Defendants”) submit this JointRule 26(f) Report pursuant to the Court’s Order of December 18, 2012, Rule 26(f)of the Federal Rules of Civil Procedure, and Central District Local Rule 26-1:I.
INFORMATION REQUESTED PURSUANT TO F.R.C.P. 26(f)A.
Initial Disclosures [F.R.C.P. Rule 26(f)(3)(A)]The parties do not believe that any changes should be made in the timing,form, or requirement for disclosures under Rule 26(a). The parties will make thedisclosures required by Rule 26(a)(1) on or before February 14, 2013.B.
Discovery [F.R.C.P. Rule 26(f)(3)(B)]Subjects on which the parties currently anticipate the need for discoveryinclude, but are not limited to, those listed below. The parties reserve the right toseek discovery on other topics that may be relevant to the issues in this case, asdiscovery unfolds and the parties’ legal theories develop.1.
Plaintiff believes that discovery will need to be taken withregard to the following topics, among others:a.
The facts and circumstances surrounding theinvestigation, writing, designing, editing, fact checking,verification, approval and publication of the covers,articles, headlines and captions and issue;b.
The identity of the individuals responsible forinvestigating, writing, designing, editing, fact checking,vetting, approving and publishing the covers, articles,headlines and captions and issue;
Case 2:12-cv-09124-DDP-JC Document 15 Filed 02/14/13 Page 2 of 7 Page ID #:77