MCCLATCHEY v. ASSOCIATED PRESS

Filing 23

MOTION for Extension of Time to File Pretrial Statements by VALENCIA M. MCCLATCHEY. (Attachments: # 1 Proposed Order)(Hall, John)

MCCLATCHEY v. ASSOCIATED PRESS

Doc. 23

Case 3:05-cv-00145-TFM

Document 23

Filed 05/30/2006

Page 1 of 4

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA
VALENCIA M. MCCLATCHEY,
Plaintiff,
v.
)

)
)

) )
) )

Civil Action No. 05-145J

THE ASSOCIATED PRESS,

JURY TRIAL DEMANDED

Defendant.

) )
)

PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO FILE PRETRIAL STATEMENTS
Plaintiff Valencia McClatchey, by and through her attorneys, hereby submits this

motion for extension of time to fie pretrial statements. In support of the motion, Plaintiff
states as follows.
1.

On January 27, 2006, this Court entered a Case Management Order and

set the following relevant dates: Close of Fact Discovery

March 15, 2006

Deadlines for Motions for Summary Judgment May 15, 2006
Plaintiff's pretrial narrative statement Defendant's pretrial narrative statement
June 2, 2006

June 26, 2006

Joint statement re: magistrate judge
2.

July 12, 2006

Since the Court's Case Management Order, the parties have

completed Fact and Expert Discovery. On May 15, 2006, Defendant filed a motion for
summary judgment. Plaintiff is currently working on a response which is due on, or

Dockets.Justia.com

Case 3:05-cv-00145-TFM

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Filed 05/30/2006

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before, June 19, 2006. Defendant's reply is due in early July. Pursuant to the current

schedule, both Plaintiff and Defendant will be preparing papers regarding summary
judgment at the same time period that pretrial narrative statements are due (June 2nd
and June 26th, respectively).
3.

Accordingly, Plaintiff seeks a short delay in the filng of the pretrial

narrative statements so that the parties can concentrate on the summary judgment
briefing. Plaintiff's proposed new dates are as follows:
Plaintiff's pretrial narrative statement Defendant's pretrial narrative statement
June 30, 2006
July 24, 2006

Joint statement re: magistrate judge

July 12, 2006

A proposed order is attached.
4.

Plaintiff's counsel contacted Defendant's counsel prior to filing this motion

but the parties could not reach agreement on a revised schedule. Defendant's counsel

agreed to a delay in the filing of the pretrial narrative statements, but wanted an
indefinite delay until after the Court had ruled on the summary judgment motion.
However, Plaintiff believes that only a short delay is warranted, thus placing the case in
a position where it is ready to be set for trial once summary judgment is decided.

Case 3:05-cv-00145-TFM

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Filed 05/30/2006

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WHEREFORE, Plaintiff respectfully request that the Court grant a short delay in
the filing of the pretrial narrative statements as indicated in the revised schedule above.

Respectfully submitted,
VALENCIA MCCLATCHEY

Is IDouglas M. Hall
Douglas M. Hall Kara L. Szpondowski Niro, Scavone, Haller & Niro

181 W. Madison, Suite 4600 Chicago, Ilinois 60602
Phone: [phone] Fax: [phone]

Is/John E. Hall
John E. Hall Eckert Seamans Cherin & Mellott 600 Grant Street, 44th Floor

Pittsburgh, PA 15219
Phone: [phone] Fax: [phone]

Case 3:05-cv-00145-TFM

Document 23

Filed 05/30/2006

Page 4 of 4

CERTIFICATE OF SERVICE

The undersigned hereby certifies that a copy of the foregoing PLAINTIFF'S
MOTION FOR EXTENSION OF TIME TO FILE PRETRIAL STATEMENTS was served
upon the below-listed counsel of record:

By

Mail:

Gayle C. Sproul Levine Sullivan Koch & Schultz, LLP 2112 Walnut St., 3rd Floor

Philadelphia, PA 19013
Phone: [phone]

By Facsimile and Mail:

Robert Penchina
Levine Sullivan Koch & Schultz, LLP 230 Park Avenue

Suite 1160 New York, NY 10169
Phone: [phone] Fax: [phone]

on this 30th day of May, 2006.

Is/John E. Hall
John E. Hall