Wilson v. The Birmingham Public Library Foundation et al

Filing 35

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

Download PDF
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. ) ) ) ) ) ) ) ) ) ) ) ) 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 2 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 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 3

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?