Parents, Families, and Friends of Lesbians and Gays, Inc. et al v. Camdenton R-III School District et al

Filing 28

MOTION for leave to file supplemental suggestions in support of motion for preliminary injunction filed by Anthony E. Rothert on behalf of All Plaintiffs. Suggestions in opposition/response due by 9/16/2011 unless otherwise directed by the court. (Attachments: # 1 Supplement Supplemental Suggestions in Support of Motion for Preliminary Injunction, # 2 Affidavit Declaration of Jane Doe)(Rothert, Anthony)

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MISSOURI
CENTRAL DIVISION

Parents, Families, and Friends of Lesbians
and Gays, Inc., et al.,
Plaintiffs,
v.
Camdenton R-III School District; et al.,
Defendants.

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No. 2:11-cv-04212-NKL

MOTION FOR LEAVE TO FILE SUPPLEMENTAL SUGGESTIONS
IN SUPPORT OF PLAINTIFFS’ MOTION FOR PRELIMINARY INJUNCTION
Come now Plaintiffs and move this Court for leave to file the attached Supplemental
Suggestions in Support of Plaintiffs’ Motion for Preliminary Injunction. In support of this
motion, Plaintiffs state:
1.

Plaintiffs have filed an amended complaint adding Jane Doe, a minor who attends
Camdenton High School, as Plaintiff. (Doc. # 24).

2.

The attached Supplemental Suggestions in Support of Plaintiffs’ Motion for
Preliminary Injunction explain Jane Doe’s standing to bring her own claims and
the harm she suffers as a result of Defendants’ action.

3.

Plaintiffs could not have included this information in their Suggestions in Support
of Motion for Preliminary Injunction because Jane Doe was not a Plaintiff at the
time those suggestions were filed.

WHEREFORE Plaintiffs move the Court for entry of an order granting them leave to file
the attached Supplemental Suggestions in Support of Motion for Preliminary Injunction.

Respectfully Submitted,

By

/s/ Anthony E. Rothert
Mark Sableman #36276
A. Elizabeth Blackwell #50270
THOMPSON COBURN LLP
One U.S. Bank Plaza
St. Louis, Missouri 63101
314-552-6000
FAX [phone]
[e-mail]
[e-mail]

Anthony E. Rothert, # 44827
Grant R. Doty, # 60788
American Civil Liberties Union of Eastern Missouri
454 Whittier Street
St. Louis, Missouri 63108
314-652-3114
FAX [phone]
[e-mail]
[e-mail]
Joshua A. Block
James Esseks
LGBT Project
ACLU Foundation
125 Broad Street, Floor 18
New York, New York 10004
[phone]
FAX [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiffs

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CERTIFICATE OF SERVICE
I hereby certify that on August 30, 2011, I electronically filed the foregoing with the
Clerk of the Court using the CM/ECF system, which sent notification of such filing to the
following:
Thomas A. Mickes
Betsey A. Helfrich
MICKES GOLDMAN O’TOOLE, LLC
555 Maryville University Drive
Suite 240
St. Louis, Missouri 63141
Attorneys for Defendants
Camdenton R-III School District
and Timothy E. Hadfield

/s/ Anthony E. Rothert

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