Saint Louis University v. Meyer

Filing 38

Consent MOTION for Extension of Time to File Response/Reply as to 32 MOTION to Compel Discovery from Defendant Based Upon Waiver of Attorney-Client Privilege, 36 MOTION for Sanctions against Defendant Avis Meyer for Spoliation of Evidence, 34 MOTION to Compel Full and Complete Interrogatory Answers from Defendant Avis Meyer by Defendant Avis Meyer. (Gill, Brian)

Saint Louis University v. Meyer

Doc. 38

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MISSOURI EASTERN DIVISION SAINT LOUIS UNIVERSITY, a Missouri benevolent corporation, Plaintiff, v. AVIS MEYER, Defendant. ) ) ) ) ) ) ) ) ) ) )

Case No. 4:07-cv-01733

CONSENTED MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANT'S DISCOVERY MOTIONS (d/e 32, 34 and 36) COMES NOW Defendant, by and through his undersigned counsel, and for his Motion for Extension of Time states to the Court as follows: 1. Plaintiff electronically filed and hand-delivered service of its discovery motions

(d/e 32, 34 and 36) upon Defendant on July 8, 2008. 2. 3. Defendant's responses to said discovery motions are due July 15, 2008. Due to press of business and ongoing settlement discussions in this case,

Defendant respectfully request an extension of time to file such responses. 4. On July 9, 2008, Defendant's had a telephone conference with Plaintiff's counsel

with regard to an extension of time to respond to said motions. Plaintiff's counsel agreed to an extension of time through and including July 23, 2008. 5. Defendant does not make the instant motion for any improper purpose or to delay

these proceedings.

Dockets.Justia.com

WHEREFORE, Defendant respectfully request and extension of time, through and including Wednesday, July 23, 2008, within which to file his responses to Plaintiff's discovery motions (d/e 32, 34, and 36). Respectfully Submitted, POLSTER, LIEDER, WOODRUFF & LUCCHESI, L.C.

By: s/ Brian J. Gill_______ Nelson D. Nolte, #53,470 Scott A. Smith, #55,870 Brian J. Gill, #57,324 12412 Powerscourt Drive, Suite 200 St. Louis, Missouri 63131-3615 [phone] [phone] (fax) E-mail: [e-mail] E-mail: [e-mail] E-mail: [e-mail] ATTORNEYS FOR DEFENDANT

CERTIFICATE OF SERVICE I hereby certify that on July 10, 2008, the foregoing was filed electronically with the Clerk of Court to be served by operation of the Court's electronic filing system upon the following: Frank B. Janoski, #3480 Bridget Hoy, #109375 Lewis, Rice & Fingersh, L.C. 500 North Broadway, Suite 2000 St. Louis, Missouri 63102 [phone] [phone] E-Mail: [e-mail] [e-mail] ATTORNEYS FOR PLAINTIFF s/Brian J. Gill 2