Monsour et al v. Menu Maker Foods Inc

Filing 41

MOTION for extension of time to Designate Experts by Plaintiffs Mark Monsour, Sheila Monsour, Monsour's, Inc.(James, Richard)

Case 6:05-cv-01204-JTM

Document 41

Filed 02/03/2006

Page 1 of 3

IN UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS MARK MONSOUR, SHEILA MONSOUR and MONSOUR'S, INC. Plaintiffs, v. MENU MAKER FOODS, INC., Defendant. ) ) ) ) ) ) ) ) ) ) )

Case No. 05-1204-MLB

MOTION TO AN EXTENSION OF TIME IN WHICH TO SERVE PLAINTIFFS' EXPERT WITNESS DISCLOSURES COME NOW the plaintiffs Mark and Sheila Monsour and Monsour's Inc., by and through their attorney of record, Dustin L. DeVaughn and Richard W. James of McDonald, Tinker, Skaer, Quinn and Herrington P.A. 1. 2. 3. Plaintiffs' expert deadline is currently due February 3, 2006. No prior extension has been requested or granted. Plaintiffs' counsel has consulted with defendant=s counsel regarding the

requested extension, and defendant=s counsel does not object to the extension. 4. The requested extension is necessary due to pressing commitments of

plaintiffs' counsel in other cases as lead counsel is in Wyoming for depositions this week and has been unable to finalize the disclosures. 5. delay. This request for extension is made in good faith and not for the purpose of

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Case 6:05-cv-01204-JTM

Document 41

Filed 02/03/2006

Page 2 of 3

WHEREFORE, by reason of the above and foregoing, plaintiffs respectfully requests an extension of ten business days, or until February 17, 2006, in which to disclose its expert witnesses. Respectfully Submitted, __/s/ Richard W. James___________ Dustin L. DeVaughn, #16559 Richard W. James, #19822 Attorney for Plaintiffs McDONALD, TINKER, SKAER, QUINN & HERRINGTON, P.A. R.H. Garvey Building 300 West Douglas Avenue, Suite 500 P.O. Box 207 Wichita, KS 67202-2909 Telephone: [phone] Fax: [phone] Email: [e-mail] [e-mail]

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Case 6:05-cv-01204-JTM

Document 41

Filed 02/03/2006

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on the 3rd day of February, 2006, I electronically filed the foregoing with the Clerk of the Court by using the CM/ECF system which will send a notice of electronic filing to the following: John Val Wachtel Alex Mitchell Klenda, Mitchell, Austerman & Zuercher, Suite 1600, 201 North Main, Wichita, KS 67202 Tele: 316.267.0221 Fax: [phone] [e-mail] Attorney for Defendant Jeffrey Eastman Keleher & Eastman Law Firm 403 N.W. Englewood Rd. Gladstone MO 64118 Business Tele: 816.452.6030 Fax: [phone] Home: 816.436.1506 Cell: 816.213.0819 [e-mail] Attorney for Defendant __/s/ Richard W. James______ Dustin L. DeVaughn, #16559 Richard W. James, #19822 Attorney for Plaintiffs McDONALD, TINKER, SKAER, QUINN & HERRINGTON, P.A. R.H. Garvey Building 300 West Douglas Avenue, Suite 500 P.O. Box 207 Wichita, KS 67202-2909 Telephone: [phone] Fax: [phone] Email: [e-mail] [e-mail]

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