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

Filing 40

MOTION to Exceed Page Limitation with Certificate of Concurrence and Certificate of Service 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

Doc. 4

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. DEFENDANTS, BLUE MOUNTAIN SCHOOL DISTRICT, DR. JOYCE ROMBERGER AND JAMES MCGONIGLE'S, MOTION TO EXCEED PAGE LIMIT AND NOW, come Defendants Blue Mountain School District, Dr. Joyce Romberger and James McGonigle, by and through their attorneys, Sweet, Stevens, Katz & Williams LLP, to submit the following Motion To Exceed Page Limit, seeking permission fro m this Court to file and serve a Brief in Support of their Motion for for Summary Judgment in excess of fifteen (15) pages, pursuant to Local Rule of Civil Procedure 7.8, and so aver: : : : : : : : : : CIVIL ACTION NO. 07-CV-585 JUDGE: JAMES M. MUNLEY

ELECTRONICALLY FILED

Dockets.Justia.com

1.

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

2.

Currently, supporting Briefs to the Parties Motion for Summary Judgments are due to this Court on December 10, 2007.

3.

Instantly, the Defendants are asking this Court to allow them to file a Brief in Support of their Motion for Summary Judgment in excess of fifteen (15) pages, pursuant to Local Rule of Civil Procedure 7.8.

4.

The Defendants anticipate that their respective Brief in Support of the Motion for Summary Judgment will exceed fifteen (15) pages but should not exceed forty-five (45) pages due to the numerous legal issues involved and the voluminous record.

5.

As evidenced in the attached Certificate of Concurrence, Plaintiffs' Counsel concurs with the Defendants' instant request to permit their Brief in Support of their Motion for Summary Judgment to exceed the fifteen (15) page limit.

WHEREFORE, for all of the foregoing reasons, the Defendants respectfully request that this Honorable Court grant their instant Motion to Exceed

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Page Limit and that they be permitted to file and serve a Brief in Support of their Motion for Summary Judgment no longer than forty-five (45) pages. Respectfully submitted, SWEET, STEVENS, KATZ & WILLIAMS LLP Date: December 5, 2007 By: /s/ Jonathan P. Riba Jonathan P. Riba, Esquire, PA88095 331 E. Butler Avenue Post Office Box 5069 New Britain, Pennsylvania 18901 t [phone] f [phone] Attorney for Defendants, Blue Mountain School District, Dr. Joyce Romberger and James McGonigle

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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. CERTIFICATE OF CONCURRENCE Pursuant to Local Rule of Civil Procedure 7.1, the undersigned counsel hereby certifies that counsel for the Plaintiffs, J.S., Terry Snyder and Steven Snyder were contacted about the Defendants' instant Motion to Exceed Page Limit, and all concurred with the aforesaid request. : CIVIL ACTION NO. : 07-CV-585 : : : JUDGE: : JAMES M. MUNLEY : : : ELECTRONICALLY FILED

SWEET, STEVENS, KATZ & WILLIAMS LLP Date: December 5, 2007 By: /s/ Jonathan P. Riba Jonathan P. Riba, Esquire, PA88095 331 E. Butler Avenue Post Office Box 5069 New Britain, Pennsylvania 18901 t [phone] f [phone] Attorney for Defendants, Blue Mountain School District, Dr. Joyce Romberger and James McGonigle

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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. CERTIFICATE OF SERVICE I, Jonathan P. Riba, Esquire, counsel for Defendants Blue Mountain School District, Dr. Joyce Romberger and James McGonigle, hereby certify that a true and correct copy of the foregoing Motion to Exceed Page Limit is available through the Court's ECF filing system and was also served by U.S. First Class Mail this day upon: : : : : : : : : : CIVIL ACTION NO. 07-CV-585 JUDGE: J AMES M. MUNLEY

ELECTRONICALLY FILED

MaryCatherine Roper, Esquire American Civil Liberties Union of PA P.O. Box 40008 Philadelphia, PA 19106

Mary Kohart, Esquire Meredith Nissen, Esquire Drinker Biddle & Reath LLP One Logan Square Philadelphia, PA 19103

SWEET, STEVENS, KATZ & WILLIAMS LLP Date: December 5, 2007 By: /s/ Jonathan P. Riba Jonathan P. Riba, Esquire, PA88095 331 E. Butler Avenue Post Office Box 5069 New Britain, Pennsylvania 18901 t [phone] f [phone] Attorney for Defendants, Blue Mountain School District, Dr. Joyce Romberger and James McGonigle

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