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)

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.

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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: [phone]
Facsimile: [phone]

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