J.S. et al v. Blue Mountain School District et al

Filing 27

Unopposed MOTION for Extension of Time to Complete Discovery and Case Management Deadlines by J.S.. (Attachments: # 1 Proposed Order)(Roper, Mary)

J.S. et al v. Blue Mountain School District et al

Doc. 27

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA

) ) ) No: 3:07-cv-585 v. ) ) BLUE MOUNTAIN SCHOOL ) DISTRICT, et al., ) ELECTRONICALLY FILED _________________________________ ) J.S., et al.

UNOPPOSED MOTION FOR EXTENSION OF DISCOVERY AND CASE MANAGEMENT DEADLINES Plaintiffs, J.S. and her parents, respectfully request an enlargement of all deadlines associated with this matter at a period of sixty (60) days, and in support thereof, avers the following: 1. This case involves relatively complicated issues of constitutional law that turn on the specific facts of the situation. 2. The current deadline for discovery is August 21, 2007. 3. Discovery in this matter has been somewhat delayed, in part, but the intervention of summer vacations and the unavailability of Plaintiffs' counsel. 4. Plaintiffs will be bringing in additional counsel who have needed some time to become familiar with the case.

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5. An additional 60 days should provide ample time for the parties to complete needed discovery. 6. Even with the proposed extension, this case should be ready for trial well within the Court's customary schedule for case completion. 7. Counsel for Defendants concurs in this request. WHEREFORE, Plaintiffs respectfully request that this Honorable Court extend by 60 days the discovery and dispositive motion deadlines set forth in the Court's Case Management Order of May 11, 2007. A form of order is submitted herewith.

Respectfully submitted, Date: August 14, 2007. /s/ Mary Catherine Roper Mary Catherine Roper AMERICAN CIVIL LIBERTIES FOUNDATION OF PENNSYLVANIA P.O. Box 40008 Philadelphia, PA 19106 (T) 215.592.1513 ext. 116 (F) 215.592-1343 [e-mail] Deborah Gordon EDUCATION LAW CENTER-PA 1315 Walnut St., Suite 400 Philadelphia, PA 19107 (T) [phone], ext. 313 (F) [phone] [e-mail] Attorneys for Plaintiffs

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Certificate of Concurrence Pursuant to LR 7.20 On or about August 3, 2007, the undersigned counsel for Plaintiffs spoke with Defendants' counsel, Ellis Katz, by telephone, and Mr. Katz stated that the Defendants concur in Plaintiffs' Motion for Extension of Discovery and Case Management Deadlines. /s/ Mary Catherine Roper MARY CATHERINE ROPER PA ID No. 71107 AMERICAN CIVIL LIBERTIES UNION OF PENNSYLVANIA P.O. Box 40008 Philadelphia, PA 19106 Tel.: [phone] ext. 116 Fax: [phone] Email: [e-mail]

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CERTIFICATE OF SERVICE

I, Mary Catherine Roper, hereby certify that on this day, the foregoing was filed with the Court and counsel below, being registered with the Court's ECF service, received service thereof:

Ellis Katz, Esq. Sweet, Stevens, Katz & Williams LLP 331 E. Butler Ave. New Britain, PA 18901 Phone: [phone] Fax: [phone]

Dated: August 14, 2007.

/s/ Mary Catherine Roper Mary Catherine Roper

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