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)

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.
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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 [phone]
Facsimile [phone]
[e-mail]
[e-mail]
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: [phone]

Daniel Mach
ACLU Foundation
915 15th Street, NWS
Washington, DC 20005
Fax: [phone]
/s/ Matt Cologna
Matt Cologna
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