Hunter v. Salem, Missouri, City of et al

Filing 45

MOTION for Extension of Time to File ;Extension to file the following: designation of neutral ;Proposed extension date December 21, 2012 by Plaintiff Anaka Hunter. (Rothert, Anthony)

Download PDF
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MISSOURI EASTERN DIVISION ANAKA HUNTER, Plaintiff, vs. CITY OF SALEM, MISSOURI, et al., Defendants. ) ) ) ) ) ) ) ) ) Case No. 4:12-CV-4 ERW MOTION FOR EXTENSION OF TIME TO COMPLY WITH ORDER REFERRING CASE TO ALTERNATIVE DISPUTE RESOLUTION Comes now Plaintiff and moves this Court for entry of an order extending from December 7, 2012, through December 21, 2012, the time for her counsel to notify the clerk of the agreed choice of neutral selected by the parties and date, time, and place of the initial ADR conference. In support, Plaintiff states: 1. On November 2, 2012, this Court entered its order referring this case to alternative dispute resolution. Doc. # 40. 2. This Court appointed one of Plaintiff’s attorneys, Anthony E. Rothert, as lead counsel responsible for working with the parties and the neutral to coordinate ADR. 3. One of the responsibilities of lead counsel is to “[n]ot later than December 7, 2012,” notify the clerk of the agreed choice of neutral selected by the parties and the date, time, and place of the initial ADR conference. 4. On November 13, 2012, Plaintiff’s counsel proposed to Defendants’ counsel four possible neutrals to conduct mediation in this case. Receiving no response, Plaintiff’s counsel discussed the issue with Defendants’ counsel during a telephone call on November 18, 2012. On 1 December 6, 2012, inquired by email about the status of a response. As of the filing of this motion, Plaintiff’s counsel has not received a response. 5. The parties have worked together amicably and have had settlement discussions; thus, Plaintiff requests a two-week extension of time, through December 21, 2012, for compliance with this Court’s order. WHEREFORE Plaintiff respectfully requests this Court enter an order extending from December 7, 2012, through December 21, 2012, the time for her counsel to notify the clerk of the agreed choice of neutral selected by the parties and date, time, and place of the initial ADR conference, and allow such other and further relief as is just and proper under the circumstances. Respectfully submitted, /s/ Anthony E. Rothert ANTHONY E. ROTHERT, #44827MO GRANT R. DOTY, #60788MO AMERICAN CIVIL LIBERTIES UNION OF EASTERN MISSOURI 454 Whittier Street St. Louis, Missouri 63108 (314) 652-3114 FAX: (314) 652-3112 tony@aclu-em.org grant@aclu-em.org DANIEL MACH AMERICAN CIVIL LIBERTIES UNION FOUNDATION 915 15th Street NW Washington, DC 20005 (202) 675-2330 FAX: (202) 546-0738 dmach@aclu.org dmach@dcaclu.org ATTORNEYS FOR PLAINTIFF 2 CERTIFICATE OF SERVICE I hereby certify that on December 8, 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/ Anthony E. Rothert 3

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?