MORT et al v. LAWRENCE COUNTY CHILDREN AND YOUTH SERVICES et al

Filing 55

MOTION for Extension of Time to Complete Discovery by ELIZABETH MORT, ALEX RODRIGUEZ. (Attachments: # 1 Proposed Order) (Dodge, Patricia)

903275.1.

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF PENNSYLVANIA
ELIZABETH MORT and ALEX
RODRIGUEZ,
Plaintiffs,
Civil Action No. 2:1 0-cv-0 143 8-DSC

V.

LAWRENCE COUNTY CHILDREN AND
YOUTH SERVICES; LAWRENCE
COUNTY; CHRISSY MONTAGUE,
Lawrence County Children and Youth
Services Caseworker; and JAMESON
HEALTH SYSTEM, INC.,
Defendants.

MOTION TO EXTEND DEADLINE FOR DISCOVERY
Plaintiffs, Elizabeth Mort and Alex Rodriguez ("Plaintiffs") by their undersigned counsel,
hereby move to enlarge the time for discovery and to extend the close of discovery until
February 20, 2012. In support thereof, the Plaintiffs aver as follows:
1.

On August 3, 2011, this Court entered an Order granting Defendant Jameson

Health System, Inc.'s ("Jameson") Motion For Extension of Time To Complete Discovery,
extending the deadline for the completion of discovery to November 22, 2011.
SeeAugust 3,
2011 Order [Docket No. 43].
2.

The parties are nearing completion of written discovery and are attempting to

resolve certain disputes regarding such written discovery.
3.

Additionally, the parties are continuing their efforts to notice and schedule the

remaining depositions.

903275.1

4.

It is respectfully submitted that extending the deadline for the close of discovery

until February 20, 2012 will permit the parties to resolve outstanding discovery issues and to
schedule and complete all depositions.
5.

Therefore, the Plaintiffs request an extension of time until February 20, 2012 to

complete discovery and a corresponding extension to related pretrial deadlines.
6.

All of the Defendants have consented to the requested extension of the deadline

for discovery.'
7.

No party will be prejudiced by the requested extension.

WHEREFORE, Plaintiffs respectfully request that this Court grant this Motion and enter
the Order attached hereto.

MEYER, UNKOVIC & SCOTT LLP

By: /s/ Patricia L. Dodge
Patricia L. Dodge
PA ID No. 35393
Antoinette Oliver
PA ID No. 206148
535 Smithfield Street
Suite 1300
Pittsburgh, PA 15222-2315
[phone]
[e-mail]
[e-mail]

The CYS Defendants consent to an extension of the discovery deadline but have indicated that
this does not represent consent to Plaintiffs' Motion for Leave to File Second Amended
Complaint [Docket No. 51].

2

903275.1

By: /s/ Sara J. Rose
Sara J. Rose
PA ID No. 204936
Witold J. Walczak
PA ID No. 62976
AMERICAN CIVIL LIBERTIES
FOUNDATION OF PENNSYLVANIA
313 Atwood Street
Pittsburgh, PA 15213
[phone]
sroseac1upa.org
vwa1czakac1upa.org

3

903275.1.

CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the within Motion to
7th
Extend Deadline for Discovery was served thisday of November, 2011, via the Court's
electronic transmission facilities pursuant to Fed. R. Civ. P. 5(b)(3) and Local Rule the
5.5 upon
following:
John C. Conti, Esquire
Richard J. Kabbert, Esquire
Dickie, McCamey & Chilcote
Two PPG Place, Suite 400
Pittsburgh, PA 15222
(Counsel for Defendant Jameson Health System, Inc.)
Marie Milie Jones, Esquire
Meyer, Darragh, Buckler, Bebenek & Eck, P.L.L.C.
U.S. Steel Tower, Suite
4850
600 Grant Street
Pittsburgh, PA 15219
(Counsel for Defendants Lawrence County, Lawrence County Children and Youth Services and
Chrissy Montague)

/s/ Patricia L. Dodge