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

Filing 52

MOTION for leave to file excess pages filed by Mark S. Sableman on behalf of All Plaintiffs. Suggestions in opposition/response due by 10/14/2011 unless otherwise directed by the court. (Attachments: # 1 Proposed Reply in Support of Motion for Preliminary Injunction, # 2 Exhibit 1, # 3 Exhibit 1A, # 4 Exhibit 1B, # 5 Exhibit 1C, # 6 Exhibit 2A (CD received by Clerk's Office w/ indication from filer that copy was provided to chambers), # 7 Exhibit 2B, # 8 Exhibit 3, # 9 Exhibit 4, # 10 Exhibit 5, # 11 Exhibit 6, # 12 Exhibit 7, # 13 Exhibit 8, # 14 Exhibit 9, # 15 Exhibit 10)(Sableman, Mark) Modified on 9/29/2011 (James, Carrie).

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.

)
)
)
)
)
)
)
)
)
)
)
)
)

Case No. 2:11-cv-04212
MOTION FOR LEAVE TO
FILE OVER-LENGTH
REPLY SUGGESTIONS IN
SUPPORT OF PLAINTIFFS’
MOTION FOR
PRELIMINARY INJUNCTION

PLAINTIFFS’ MOTION FOR LEAVE TO FILE OVER-LENGTH
REPLY SUGGESTIONS IN SUPPORT OF
PLAINTIFFS’ MOTION FOR PRELIMINARY INJUNCTION
Come now Plaintiffs, pursuant to Local Rule 7.1, and respectfully move this Court for
Leave to File Over-Length Reply Suggestions in Support of Plaintiffs’ Motion for Preliminary
Injunction. In support of their motion, Plaintiffs state:
1.

Plaintiffs seek leave to deviate from the page limitation of Local Rule 7.1(f),
which provides, inter alia., “Reply suggestions shall be limited to 10 doublespaced pages, unless authorized by the Court. Suggestions exceeding 10 pages in
length shall have a table of contents and table of authorities.”

2.

Defendants’ Suggestions in Opposition to Plaintiffs’ Motion for Preliminary
Injunction presents several legal arguments and raises significant factual issues.
Defendants also have attached to their brief the affidavits of two witnesses.

3.

In addition to responding to Defendants’ brief and the affidavits attached thereto,
Plaintiffs must also respond to the numerous arguments raised in the Brief of

1

Amici Curiae Alliance Defense Fund & Missouri Family Policy Council in
Opposition to Plaintiffs’ Motion for Preliminary Injunction and in Support of
Defendants’ Motion to Dismiss.
4.

Plaintiffs will be unable to adequately respond to the legal and factual issues
raised in both Defendants’ brief and the amici’s brief in ten pages.

5.

A copy of the proposed over-length suggestions is attached hereto.

WHEREFORE Plaintiffs move this Court for leave to file over-length Reply Suggestions
in Support of Plaintiffs’ Motion for Preliminary Injunction and for such other and further relief
as is appropriate under the circumstances.

Respectfully Submitted,
THOMPSON COBURN LLP

By

/s/ Mark Sableman
Mark Sableman #36276
A. Elizabeth Blackwell#50270
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

2

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

3

CERTIFICATE OF SERVICE
I hereby certify that on September 26, 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

Michael Whitehead
WHITEHEAD LAW FIRM, LLC
City Center Square
1100 Main Street, Suite 2600
Kansas City, Missouri 64105-5194

Attorneys for Defendants
Camdenton R-III School District
and Timothy E. Hadfield

Jeremy D. Tedesco
ALLIANCE DEFENSE FUND
15100 North 90th Street
Scottsdale, Arizona 85260
David A. Cortman
ALLIANCE DEFENSE FUND
1000 Hurricane Shoals Rd., N.E.
Suite D-600
Lawrenceville, GA 30043
Travis C. Barham
ALLIANCE DEFENSE FUND
12 Public Square
Columbia, Tennessee 38401
Attorneys for Amici Curiae
Alliance Defense Fund and
Missouri Family Policy Council

/s/ Mark Sableman

4