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

Filing 38

Joint MOTION for Extension of Time to To File Supporting Briefs to Dispositive Motions and Subsequent Reply Briefs by Joyce E. Romberger, James S. McGonigle, Blue Mountain School District. (Attachments: # 1 Proposed Order)(Riba, Jonathan)

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

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IN THE UNITED STATES COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA

J.S., a minor, by and through her parents, TERRY SNYDER and STEVEN SNYDER, individually and on behalf of their daughter, Plaintiffs, v. BLUE MOUNTAIN SCHOOL DISTRICT; DR. JOYCE E. ROMBERGER, Superintendent Blue Mountain School District; and JAMES S. MCGONIGLE, Principal Blue Mountain Middle School, both in their official and individual capacities, Defendants.

: CIVIL ACTION NO. 07-CV: 585 : : : JUDGE: JAMES M. : MUNLEY : : : ELECTRONICALLY FILED

PARTIES' JOINT MOTION FOR EXTENSION OF TIME TO FILE SUPPORTING BRIEFS TO DISPOSITIVE MOTIONS AND SUBSEQUENT REPLY BRIEFS AND NOW, come Plaintiffs J.S., Terry Snyder and Steven Snyder (hereinafter referred to as "Plaintiffs"), Defendants Blue Mountain School District, Dr. Joyce Romberger and James S. McGonigle (hereinafter referred to as "Defendants") and collectively with Plaintiffs and Defendants referred to as "Parties"), by and through their undersigned counsel, to submit the following Joint Motion for Extension of time to file Supporting Brief and Subsequent Reply Briefs and aver the following:

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1.

On November 21, 2007, the Parties filed their respective Motions for Summary Judgment.

2.

Pursuant to Local Rule of Civil Procedure 7.5, Supporting Briefs are due on or before December 3, 2007.

3.

Due to the overall complexity of the matter and given that Defense Counsel is preparing for trial that is set to begin on December 11, 2007 in the United States District Court for the Eastern District of Pennsylvania, the Parties jointly and respectfully request a brief one week extension, until December 10, 2007, to file supporting briefs.

4.

Additionally, the Parties request that their respective responses to the Summary Judgment Motions be extended from December 25, 2007 until January 7, 2008 to accommodate counsels' schedules during the Holidays.

5.

The instant extension request should not alter any of the other deadlines established by this Court's August 20, 2007 Order or significantly delay resolution of this case. WHEREFORE, for all of the foregoing reasons, the Parties jointly and

respectfully request that this Honorable Court grant their instant Motion to Extend Case Filing Deadlines and enter the attached Order.

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Respectfully submitted, By: /s/ Jonathan P. Riba By: /s/ MaryCatherine Roper

Sweet, Stevens, Katz & Williams LLP 331 East Butler Ave New Britain, PA 18901 Attorney for Defendants

American Civil Liberties Union of PA P.O. Box 40008 Philadelphia, PA 19106 Attorney for Plaintiffs

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