Hunter v. Salem, Missouri, City of et al

Filing 35

Consent MOTION for Extension of: Time for Plaintiff to Make Expert Disclosures by Plaintiff Anaka Hunter. (Doty, Grant)

IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION
ANAKA HUNTER,

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Plaintiff,
v.
BOARD OF TRUSTEES, SALEM PUBLIC
LIBRARY, et al.,
Defendants.

CONSENT MOTION FOR EXTENSION OF TIME FOR PLAINTIFF TO MAKE EXPERT DISCLOSURES
Comes now Plaintiff, with the consent of Defendants, and moves this Court to modify the
Case Management Order (Doc. # 30) to allow the Plaintiff until September 28, 2012, to disclose
experts and provide expert reports and until October 19, 2012, to make experts available for
depositions and have depositions completed. In support, Plaintiff states:
1.

Pursuant to the Case Management Order, Plaintiff must disclose any experts and

provide expert reports no later than August 31, 2012, and make experts available for depositions
and have depositions completed by September 14, 2012.
2.

A Rule 30(b)(6) deposition of Board of Trustees, Salem Public Library was

scheduled for Friday, August 24, 2012. Defendants’ counsel contacted Plaintiff’s counsel today
(August 21, 2012) and asked to postpone this deposition due to an unforeseen scheduling
conflict.
3.

Because completion of the deposition is necessary for Plaintiff to ascertain

whether experts are required and for any experts to prepare their reports, Plaintiff asks for, and
Defendants consent to, this requested extension.

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4.

A grant of additional time to disclose experts will not require a change to the

November 16, 2012, deadline for the completion of all discovery; the January 11, 2013, deadline
for dispositive motions; or the June 24, 2013, trial setting.

WHEREFORE Plaintiff moves this Court, with the consent of Defendants, for entry of an order
modifying the Case Management Order (Doc. # 30) to allow the Plaintiff until September 28,
2012, to disclose experts and provide expert reports and until October 19, 2012, to make experts
available for depositions and have depositions completed, and such other relief as is proper under
the circumstances.
Respectfully submitted,
/s/ Grant R. Doty
ANTHONY E. ROTHERT, #44827MO
GRANT R. DOTY, #60788MO
AMERICAN CIVIL LIBERTIES UNION OF
EASTERN MISSOURI
454 Whittier Street
St. Louis, Missouri 63108
PHONE: [phone]
FAX: [phone]
[e-mail]
[e-mail]
DANIEL MACH
AMERICAN CIVIL LIBERTIES
UNION FOUNDATION
915 15th Street NW
Washington, DC 20005
[phone]
FAX: [phone]
[e-mail]
ATTORNEYS FOR PLAINTIFF

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CERTIFICATE OF SERVICE
I hereby certify that on August 21, 2012, I electronically filed the foregoing with the
Clerk of the Court using the CM/ECF system and a copy was made available electronically to all
electronic filing participants.

/s/ Grant R. Doty

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