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)

IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION
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) No. 4:12-CV-4 ERW
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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.

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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: [phone]
Fax: [phone]
DANIEL MACH
AMERICAN CIVIL LIBERTIES
UNION FOUNDATION
915 15th Street NW
Washington, DC 20005
Phone: [phone]
FAX: [phone]
Attorneys for Plaintiff

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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

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