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)

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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. ) ) ) ) ) ) ) ) ) ) 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 314-552-7000 msableman@thompsoncoburn.com eblackwell@thompsoncoburn.com 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 314-652-3112 tony@aclu-em.org grant@aclu-em.org Joshua A. Block James Esseks LGBT Project ACLU Foundation 125 Broad Street, Floor 18 New York, New York 10004 (212) 549-2600 FAX 212-549-2650 jblock@aclu.org jesseks@aclu.org Attorneys for Plaintiffs -2- 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 -3-

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