Hunter v. Salem, Missouri, City of et al

Filing 37

Consent MOTION for Extension of Time to Complete Discovery Consent Motion for Extension of Time for Defendants to Disclose Experts by Defendants Board of Trustees, Salem Public Library, Glenda Woffard. (Cologna, Matt)

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IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION ANAKA HUNTER, ) ) Plaintiff, ) ) vs. ) ) CITY OF SALEM, MISSOURI, ) BOARD OF TRUSTEES, Salem Public ) Library, and GLENDA WOFFORD, ) Individually, and in her official capacity ) As Director of the Salem Public Library, ) ) Defendants. ) Case No: 4:12-CV-0004-ERW JURY TRIAL DEMANDED CONSENT MOTION FOR EXTENSION OF TIME FOR DEFENDANTS TO DISCLOSE EXPERTS COMES NOW Defendants Glenda Wofford and the Board of Trustees of the Salem Public Library, by and through their attorneys of record, Baird, Lighter, Millsap & Harpool, P.C., with the consent of Plaintiff and move this Court to extend the time in which to disclose experts for the following reasons: 1. This Court previously granted Plaintiff an extension from the August 31 deadline to September 28 to disclose Plaintiff’s experts. 2. Defendants received Plaintiff’s expert’s report on October 1. 3. When the Court extended Plaintiff’s deadline, it did not adjust the deadline by which Defendants are to disclose their experts, which is currently October 5. 4. Counsel for Plaintiff and Defendants agreed to extend the deadline for Defendant’s expert disclosure to November 7, to extend the deadline for expert depositions until November 21, and to extend the deadline for discovery to December 7, accordingly. 1 5. The extension will not impact the January 11, 2013, deadline for dispositive motions or the June 24, 2013 trial setting. WHEREFORE, Defendants, with the consent of Plaintiff, pray this court to grant an extension of time to disclose their experts until November 7, 2012, an extension of time to produce those experts until November 21, and to extend the deadline for discovery until December 7. Respectfully submitted, BAIRD, LIGHTNER, MILLSAP & HARPOOL, P.C. By: /s/Matt Cologna M. DOUGLAS HARPOOL #28702 MATT COLOGNA #62020 1901-C South Ventura Avenue Springfield, MO 65804-2700 Telephone (417) 887-0133 Facsimile (417) 887-8740 Attorneys for Defendants CERTIFICATE OF SERVICE I hereby certify that on the 5th day of October, 2012, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which provided a copy of same to the below listed counsel of record: Anthony E. Rothert Grant R. Doty ACLU of Eastern Missouri 454 Whittier Street St. Louis, MO 63108 Fax: 324-652-3112 Daniel Mach ACLU Foundation 915 15th Street, NWS Washington, DC 20005 Fax: 202-546-0738 /s/ Matt Cologna Matt Cologna 2

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