Hunter v. Salem, Missouri, City of et al

Filing 55

STATEMENT of Material Facts re 54 MOTION for Summary Judgment filed by Plaintiff Anaka Hunter. (Attachments: # 1 Exhibit Ex. P-1, # 2 Exhibit Ex. P-2, # 3 Exhibit Ex. P-3, # 4 Exhibit Ex. P-4, # 5 Exhibit Ex. P-4A, # 6 Exhibit Ex. P-5, # 7 Exhibit Ex. P-6, # 8 Exhibit Ex. P-7, # 9 Exhibit Ex. P-8, # 10 Exhibit Ex. P-9, # 11 Exhibit Ex. P-10, # 12 Exhibit Ex. P-11, # 13 Exhibit Ex. P-12, # 14 Exhibit Ex. P-13, # 15 Exhibit Ex. P-14, # 16 Exhibit Ex. P-15, # 17 Exhibit Ex. P-16, # 18 Exhibit Ex. P-17, # 19 Exhibit Ex. P-18, # 20 Exhibit Ex. P-19, # 21 Exhibit Ex. P-20, # 22 Exhibit Ex. P-21, # 23 Exhibit Ex. P-22 - Part 1 of 4, # 24 Exhibit Ex. P-22 - Part 2 of 4, # 25 Exhibit Ex. P-22 - Part 3 of 4, # 26 Exhibit Ex. P-22 - Part 4 of 4, # 27 Exhibit Ex. P-23, # 28 Exhibit Ex. P-24, # 29 Exhibit Ex. P-25, # 30 Exhibit Ex. P-26, # 31 Exhibit Ex. P-27, # 32 Exhibit Ex. P-28, # 33 Exhibit Ex. P-29, # 34 Exhibit Ex. P-30, # 35 Exhibit Ex. P-31)(Rothert, Anthony)

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

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) No. 4:12-CV-4 ERW
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Plaintiff,
v.
BOARD OF TRUSTEES, SALEM PUBLIC
LIBRARY, et al.,
Defendants.

DECLARATION OF GRANT R. DOTY
I, Grant R. Doty, declare as follows:
1.

My name is Grant R. Doty and I am one of the attorneys for the Plaintiff in the

above captioned matter.
2.

I am over the age of 18 and legally competent to make a declaration and do so

on the basis of personal knowledge.
3.

On October 15, 2012, I served the Plaintiff’s First Request for Admissions

directed to Defendant Wofford in accordance with Fed.R.Civ.P. 36 (Attachment A).
4.

Under Fed.R.Civ.P. 36(a)(3) the response to the Plaintiff’s request was due on

November 14, 2012.
5.

Defendant Wofford has not served on Plaintiff or Plaintiff’s attorneys any

written answers or objections addressed to the matters and signed by Wofford or her attorneys.
6. Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is
true and correct.
Executed on February 22, 2012.
/s/ Grant R. Doty
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