Wilson v. The Birmingham Public Library Foundation et al

Filing 35

MOTION for Leave to File Excess Pages by Barbara Ann Wilson. (Morel, Adam)

FILED
2011 Aug-17 PM 08:04
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 CITY OF BIRMINGHAM;
et al.,

Defendants.

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2:10-cv-02386-KOB

PLAINTIFF’S MOTION TO ALLOW ADDITIONAL PAGES
The Plaintiff, through undersigned counsel, respectfully requests an Order
allowing additional pages in her contemporaneously filed brief in Response to
Defendants’ Motion for Summary Judgment. As support for this Motion, the Plaintiff
states the following:
1.

This case is being prosecuted against two Defendants.

2.

A total of ten depositions were taken in the case the transcripts of which
are comprised of several hundred pages and to which the Plaintiff alone,
attached 36 exhibits. The depositions covered facts occurring over a
several year period.

3.

The Defendants posited a number of legal arguments in their brief to

which the Plaintiff responded.
4.

The Plaintiff endeavored to be concise and address only material,
relevant factual and legal issues which are before the Court.
Nonetheless, due to the breadth of the testimony and importance of the
issues in the case, the Plaintiff’s brief exceeds the 30 page limit set by
this Court’s Order pertaining to dispositive motions. Not counting the
cover page, table of contents or certificate of service, the Plaintiff’s brief
totals 40 pages.

5.

The Plaintiff would suffer severe prejudice should any portion of her
brief and attendant legal and factual arguments be stricken.

6.

The Defendants will suffer no prejudice should this Motion be granted.

WHEREFORE, the Plaintiff respectfully requests entry of an Order allowing
her to file additional pages in her brief in Response to Defendant’s Motion for
Summary Judgement.
Respectfully submitted,

s/Adam P. Morel
Adam P. Morel
ATTORNEY FOR THE PLAINTIFF

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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 on August 17, 2011, I electronically filed the foregoing
with the Clerk of the Court using the CM/ECF system which will send notification
of such filing to all attorneys of record.

s/Adam P. Morel
OF COUNSEL

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