Monsour et al v. Menu Maker Foods Inc

Filing 62

MOTION for extension of time WITHIN WHICH TO SERVE EXPERT WITNESS DISCLOSURES UPON PLAINTIFFS by Defendant Menu Maker Foods Inc (Wachtel, John)

Monsour et al v. Menu Maker Foods Inc

Doc. 62

Case 6:05-cv-01204-JTM

Document 62

Filed 03/08/2006

Page 1 of 2

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

Case No. 05-1204-MLB

DEFENDANT'S MOTION FOR EXTENSION OF TIME WITIN WHICH TO SERVE EXPERT WITNESS DISCLOSURES UPON PLAINTIFFS COMES NOW the Defendant, by and through its attorney of record, John Val Wachtel of Klenda, Mitchell, Austerman & Zuercher, L.L.C., and hereby moves this Court for an order extending the time within which the Defendant must serve expert witness disclosures on the Plaintiffs. In support of the motion, the Defendant states: 1. Defendant's deadline was March 6, 2006. 2. No prior extensions have been granted to the Defendant. 3. Prior to the expiration of the extension deadline counsel for the Defendant and counsel for the Plaintiffs had discussed the necessity of granting additional time to the Defendant, which arose out of the agreed order granting the Plaintiff additional time to make expert disclosures. 4. The extension of time is necessary due to pressing engagements of Defendant's expert and due to the extension of time granted to the Plaintiffs. 5. This request has been made in good faith and is not for the purpose of delay. WHEREFORE, the Defendant prays for an order of this Court granting an extension of time within which to serve expert witness disclosure until April 3, 2006.

Dockets.Justia.com

Case 6:05-cv-01204-JTM

Document 62

Filed 03/08/2006

Page 2 of 2

Respectfully submitted, KLENDA, MITCHELL, AUSTERMAN & ZUERCHER, L.L.C. s/John Val Wachtel John Val Wachtel, #8310 Alexander B. Mitchell, #8204 301 N. Main, 1600 Epic Center Wichita, KS 67202-4888 Tele.: [phone] Fax: [phone] [e-mail] [e-mail] CERTIFICATE OF SERVICE The undersigned hereby certifies that on the 8th day of March, 2006, I electronically filed the foregoing with the Clerk of the Court by using the CM/ECF system which will send electronic notice of this filing to: Dustin DeVaughn McDonald, Tinker, Skaer, Quinn & Herrington, P.A. 200 W. Douglas, Ave., Ste. 500 Wichita, KS 67202 [e-mail] Attorney for Plaintiff

s/John Val Wachtel John Val Wachtel

KMAZ Document No. 300275

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