Massachusetts Bay Transportation Authority v. Anderson et al

Filing 39

Emergency MOTION for Extension of Time to 5:00/PT 8:00 ET August 16, 2008 to Complete Discovery Response by Zack Anderson, RJ Ryan, Alessandro Chiesa. (Attachments: # 1 Declaration of Kurt Opsahl, # 2 Text of Proposed Order)(Reinstein, John)

Massachusetts Bay Transportation Authority v. Anderson et al

Doc. 39

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACUSETTS MASSACHUSETTS BAY TRANSPORTATION AUTHORITY, Plaintiff, v. ZACK ANDERSON, RJ RYAN, ALESSANDRO CHIESA, AND THE MASSACHUSETTS INSTITUTE OF TECHNOLOGY, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

CIVIL ACTION NO. 08-11364-GAO

MOTION FOR AN EXTENSION OF TIME TO RESPOND TO AUGUST 14, 2008 DISCOVERY ORDER Defendants Anderson, Ryan and Chiesa ("students") hereby move for a short extension of time to respond to the Court's August 14, 2008 order requiring production or responses to particular document requests submitted by the plaintiff no later than 1:00 PT/4:00 ET today, August 15, 2008. This extension is necessary because the students' lead counsel, Jennifer Granick, has encountered numerous travel-related complications that have delayed her return to San Francisco and rendered her unable to review the response to the document requests underlying the Court's order. Declaration of Kurt Opsahl ("Opsahl Decl.") ¶ 3. Ms. Granick's flight is expected to land in San Francisco at approximately 12:00 PT/3:00 ET this afternoon, and she will be unable to review the response in consultation with her colleagues until late afternoon ET today, after the Court-ordered discovery deadline has passed. Opsahl Decl. ¶ 4. Counsel for the students have requested opposing counsel's consent to an

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extension of the deadline, but opposing counsel has not responded. Opsahl Decl. ¶ 5. To permit Ms. Granick a reasonable opportunity to review the response to the discovery request and confer with her colleagues, we respectfully request that the Court extend the discovery deadline to 4:00 PT/8:00 ET on August 16, 2008.

Respectfully submitted, /s/ John Reinstein______ John Reinstein, BBO #416120 ACLU of Massachusetts 211 Congress Street, 3rd Floor Boston, MA 02110 Tel: [phone] [e-mail] Jennifer Stisa Granick, CA Bar No. 168423 [e-mail] Kurt Opsahl, CA Bar No. 191303 [e-mail] Marcia Hofmann, CA Bar No. 250087 [e-mail] ELECTRONIC FRONTIER FOUNDATION 454 Shotwell St. San Francisco, CA 94110 [phone] [phone] (fax) Counsel for Defendants Anderson, Ryan and Chiesa

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