Hunter v. Salem, Missouri, City of et al

Filing 57

MOTION for Leave to File in Excess of Page Limitation by Plaintiff Anaka Hunter. (Attachments: # 1 Proposed memorandum in support)(Rothert, Anthony)

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IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION ) ) ) ) ) No. 4:12-CV-4 ERW ) ) ) ) ) ANAKA HUNTER, Plaintiff, v. BOARD OF TRUSTEES, SALEM PUBLIC LIBRARY, et al., Defendants. MOTION FOR LEAVE TO FILE MEMORANDUM IN SUPPORT OF PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT IN EXCESS OF PAGE LIMITATION Come now Plaintiffs pursuant E.D.MO. L.R. 4.01(D) and, with consent of Defendants, move this Court for leave to file a memorandum of twenty-six pages, exclusive of signature pages. In support, she states: 1. Pursuant to E.D.MO. L.R. 4.01(D), “No party shall file any motion, memorandum or brief which exceeds fifteen (15) numbered pages, exclusive of the signature page and attachments, without leave of Court.” 2. Plaintiff’s memorandum in support of her motion for summary judgment is twenty-six pages in length, exclusive of the certificate of service page and attachments. 3. Additional pages are needed to describe why entry of summary judgment, the award of nominal damages, and issuance of a permanent injunction are appropriate. 4. A copy of Plaintiff’s proposed memorandum in support is attached hereto. 1 WHEREFORE Plaintiff moves this Court for leave to file the memorandum in support that is in excess of the page limitation and for 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 UNIONOF EASTERN MISSOURI 454 Whittier Street St. Louis, Missouri 63108 Phone: 314/652-3114 Fax: 314/652- 3112 DANIEL MACH AMERICAN CIVIL LIBERTIES UNION FOUNDATION 915 15th Street NW Washington, DC 20005 Phone: (202) 675-2330 FAX: (202) 546-0738 Attorneys for Plaintiff 2 CERTIFICATE OF SERVICE I hereby certify that on February 25, 2013, 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

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