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

Filing 57

Joint MOTION for Extension of Time to March 31, 2009 to Complete Discovery and Related Extensions by Friends of Wareham Free Library, Inc..(Gallitano, Thomas)

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

Doc. 57

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS Civil Action 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., ) ) Plaint iffs / Defendants in Counterclaim / ) Third Party Plaintiffs, ) ) v. ) ) THE TOWN OF WAREHAM, ) ) Defendant / Plaintiff in Counterclaim, ) ) and ) ) BRENDA ECKSTROM, BRUCE SAUVAGEAU, JOHN ) CRONAN, JAMES PORTER, and M. JANE DONAHUE, ) Individually and As Members of The Board of Selectman ) of Wareham, ) ) Defendants, ) ) v. ) ) FRIENDS OF THE WAREHAM FREE LIBRARY, INC. and ) THE WAREHAM LIBRARY FOUNDATION, INC., ) ) Defendants in Counterclaim, ) ) v. ) MASSACHUSETTS INTERLOCAL INSURANCE ASSOC. ) ) Third Party Defendant. ) ______________________________________________________) JOINT MOTION TO EXTEND DISCOVERY PERIOD

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NOW COME ALL PARTIES to the action and jointly move, pursuant to Local Rule 26.2(B), that the deadlines for taking of fact depositions, completing and exchanging expert disclosures, and filing and serving motions for summary judgment each be extended by approximately two months, as described in more detail below. In support of this motion, the parties state that due to the challenges associated with scheduling depositions for each of the individually named parties (and, in the case of organizations, individuals designated as Rule 30(b)(6) deponents for those parties) on dates and at times that are convenient to all counsel of record, the parties agree that they will be able to conclude all such fact depositions by the end of March 2009. Accordingly, the parties jointly request that the deadlines established by this Court's order of June 18, 2008 be enlarged as follows: Fact depositions completed by March 31, 2009; Expert disclosures must be completed and exchanged by May 15, 2009; and Any motion for summary judgment must be filed by June 19, 2009.

Respect fully submitted, Plaint iffs/Defendants in Counterclaim Third Party Plaintiffs By their attorneys, ___/s/ Philip N. Beauregard Philip N. Beauregard (BBO 034870) Timour Zoubaidoulline (BBO 656212) BEAUREGARD, BURKE & FRANCO 32 William Street New Bedford, MA 02740 [phone] [e-mail] [e-mail] Plaint iff in Counterclaim The Town of Wareham By its attorneys, ____/s/ Elizabeth Corbo Richard Bowen (BBO 552814) Elizabeth Corbo (BBO 640131) KOPELMAN & PAIGE 101 Arch Street, 12th Floor Boston, MA 02110 [phone] [e-mail] [e-mail]

Defendants, Officially and Individually By their attorneys, ___/s/ Peter E. Montgomery Leonard H. Kesten (BBO 542042) Peter E. Montgomery (BBO 632698) BRODY, HARDOON, PERKINS & KESTEN One Exeter Plaza Boston, MA 02116 [phone] [e-mail] [e-mail]

Defendant in Counterclaim Friends of the Wareham Free Library, Inc. By its attorney, ____/s/ Thomas J. Gallitano Thomas J. Gallitano (BBO 550745) Lurleen A. Gannon (BBO 655109) CONN KAVANAUGH ROSENTHAL PEISCH & FORD Ten Post Office Square Boston, MA 02109 [phone] [e-mail] m [e-mail] m

Third Party Defendant Massachusetts Interlocal Insurance Association By its attorney, ___/s/ Arthur E. Maravelis Arthur E. Maravelis (BBO 564673) TANG & MARAVELIS 50 Mall Road, Suite 111 Burlington, MA 01803 [phone] [e-mail]

Dated: January 21, 2009

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