Wareham Free Library et al v. Wareham, Town of et al

Filing 25

Emergency MOTION for Extension of Time to February 19, 2008 to File Memorandum Concerning The Basis For Plaintiffs' Federal Claim by Wareham Free Library, Inc.,, Priscilla Porter, Mary Nyman, Hazal Taber, Michelle Baum, Sandra Wheeler, John Lanci, Martha Maguire, Yelena Farioli-Beaupre, Diane Lazarus.(Zoubaidoulline, Timour)

Wareham Free Library et al v. Wareham, Town of et al

Doc. 25

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS DOCKET NO. 07-CV-11807 RGS WAREHAM FREE LIBRARY, INC. and PRISCILLA PORTER, MARY NYMAN, HAZEL TABER, MICHELLE BAUM, SANDRA WHEELER, JOHN LANCI, MARTHA MAGUIRE, YELENA FARIOLI-BEAUPRE, and DIANE LAZARUS, Individually and As Trustees of Wareham Free Library, Inc. Plaintiffs / Defendants in Counterclaim / Third Party Plaintiffs v. THE TOWN OF WAREHAM Defendant / Plaintiff in Counterclaim and BRENDA ECKSTROM, BRUCE SAUVAGEAU, JOHN CRONAN, JAMES POTTER, and M. JANE DONAHUE, Individually and As Members of The Board of Selectmen of Wareham Defendants v. FRIENDS OF THE WAREHAM FREE LIBRARY, INC., Defendant in Counterclaim v. MASSACHUSETTS INTERLOCAL INSURANCE ASSOCIATION Third Party Defendant PLAINTIFFS' (UNOPPOSED) EMERGENCY MOTION FOR AN EXTENSION TO FILE A MEMORANDUM CONCERNING THE BASIS FOR PLAINTIFFS' FEDERAL CLAIM

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At the Scheduling Conference on January 23, 2008, the Court ordered Plaintiffs to file a memorandum within three weeks of the Conference advising the Court of the basis for Plaintiffs' Federal claim in this case. Plaintiffs respectfully request a short, six-day extension for filing said memorandum to next Tuesday, February 19, 2008. In support, Plaintiffs state that their undersigned counsel had a heavy litigation schedule in the past three weeks, including a trial of another matter in the Massachusetts Bristol County Superior Court, Docket No. BRCV2005-01382, and did not have sufficient time to prepare said memorandum. The requested one-week extension will not prejudice rights of any parties in this action. In further support, Plaintiffs state that this motion has been assented to by Defendant in Counterclaim Friends of the Wareham Free Library, Inc. and Third Party Defendant Massachusetts Interlocal Insurance Association. Plaintiffs' undersigned counsel was also advised by counsel for Defendants Town of Wareham and the Board of Selectmen that said Defendants do not assent to this motion, but do not oppose it either. For all these reasons, Plaintiffs respectfully request that this Motion be allowed.

Respectfully submitted,

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PLAINTIFFS / DEFENDANTS IN COUNTERCLAIM / THIRD PARTY PLAINTIFFS By Their Attorneys, / S / Timour Zoubaidoulline _________________________________ Timour Zoubaidoulline, BBO # 656212 BEAUREGARD, BURKE & FRANCO 32 William Street New Bedford, MA 02740 Tel. [phone] [e-mail] [e-mail] Dated: February 13, 2008

CERTIFICATE OF SERVICE In accordance with the Electronic Case Filing ("ECF") Administrative Procedures of the United States District Court for the District of Massachusetts, I, Timour Zoubaidoulline, hereby certify that the foregoing document(s) filed through the ECF system will be sent electronically to the registered participants as identified on the Notice of Electronic Filing ("NEF") and that paper copies will be sent to those indicated as non-registered participants by first class mail on February 13, 2008. / S / Timour Zoubaidoulline ________________________________________ TIMOUR ZOUBAIDOULLINE, BBO # 656212

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