Wilson v. The Birmingham Public Library Foundation et al

Filing 34

MOTION for Extension of Time to File Response/Reply as to 31 MOTION for Summary Judgment by Barbara Ann Wilson. (Morel, Adam)

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FILED 2011 Aug-02 PM 12:12 U.S. DISTRICT COURT N.D. OF ALABAMA IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION BARBARA ANN WILSON, Plaintiff, v. THE BIRMINGHAM PUBLIC LIBRARY FOUNDATION; et al., Defendants. ) ) ) ) ) ) ) ) ) ) ) 2:10-cv-02386-KOB OPPOSED PLAINTIFF’S MOTION FOR EXTENSION The Plaintiff, through undersigned counsel, files this Motion respectfully requesting entry of an Order extending the date by which she must respond to Defendants’ Motion to for Summary Judgment by seven days. As grounds for this motion, the Plaintiff states the following: 1. Plaintiff’s response to Defendants’ Motion for Summary Judgment is presently due August 10, 2011. 2. The undersigned, a solo practitioner and Plaintiff’s sole counsel, has several conflicts the same week Plaintiff’s response is due including an appellate brief deadline and an out of town administrative bench trial. 3. The conflicts described above prevent the undersigned from adequately preparing and filing Plaintiff’s response by the present deadline. 4. No party would be prejudiced by an Order granting this Motion. 5. An Order granting this Motion would cause no undue delay in the adjudication of this case. 6. Counsel for the Defendants’ has represented to the undersigned that his clients oppose this Motion. Wherefore, the Plaintiff respectfully requests entry of an Order extending the date by which she must file her response in opposition to the Defendants’ Motion for Summary Judgment by seven days or until Wednesday, August 17, 2011. Respectfully submitted, s/Adam P. Morel Adam P. Morel ATTORNEY FOR PLAINTIFF OF COUNSEL: LAW OFFICES OF ADAM MOREL, P.C. 517 Beacon Parkway West Birmingham, AL 35209 Telephone: (205) 252-8841 Facsimile: (205) 252-3727 CERTIFICATE OF SERVICE I hereby certify that a copy of the above has been served on all counsel of record via electronic filing. This the 2nd day of August, 2011. s/Adam P. Morel OF COUNSEL

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