Bradburn et al v. North Central Regional Library District

Filing 14

Joint MOTION to Expedite Hearing Re: Motion to Modify Case Scheduling Order by North Central Regional Library District. (Adams, Thomas)

Bradburn et al v. North Central Regional Library District

Doc. 14

Case 2:06-cv-00327-EFS

Document 14

Filed 09/13/2007

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The Honorable Edward F. Shea
Thomas D. Adams

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3 Celeste Mountain Monroe

4 KARR TUTTLE CAMPBELL
5 1201 Third Avenue, Suite 2900

Seattle, Washington 98101-3028

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7 Attorneys for North Central Regional Library District
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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON AT SPOKANE

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SARH BRADBUR, PEAR

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CHERRGTON, CHAES
HEINEN, and THE SECOND

AMENDMENT FOUNATION,
Plaintiffs,
v.

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NORTH CENTRAL REGIONAL LIBRARY DISTRICT,

) ) ) NO. CV-06-327-EFS ) ) JOINT MOTION FOR ) HEARING ) ) ) ) ) )
) )

EXPEDITED

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Defendant.

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The parties move the Court to grant their Joint Motion for Expedited
Hearing. The parties further request that the Court hear their Motion to Amend

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JOINT MOTION FOR EXPEDITED HEARING - 1
CV-06-327-EFS
#642220 vI /42703-001

Law Offces

KARR TUTTLE CAMPBELL
A Professional Service Corporation
IZUI Tbird Avenue, Suite 29t)), Sea"lc, WlishiDglOD 98101-JlJ28 Telephone [phone], Facsimile [phone]

Dockets.Justia.com

Case 2:06-cv-00327-EFS

Document 14

Filed 09/13/2007

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the Case Scheduling Order on September 14, 2007 without oral argument. Good
cause exists for this request.

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On February 27, 2007, the Court entered a scheduling order in the above-

captioned case following a telephonic status conference with counseL. The
parties stipulated to a modification of the case schedule and acted in reliance
upon it. This stipulation was filed on June 28, 2007, however, it was never
entered by the Court.

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Under the operative case scheduling order entered in February 2007, the

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discovery cut off is Friday, September 14, 2007. By its motion to Amend the
Case Scheduling Order, the parties request the Court extend the discovery cut

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off, and other critical dates primarily to allow for the completion of expert
discovery. For this reason, the parties respectfully request that the Court grant
their motion for expedited hearing and that it rule on their Motion to Amend the
Case Schedule on Friday, September 14, 2007.

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NCRL has confirmed that Plaintiffs' counsel has no objection to this
Motion for Expedited Hearing. Similarly, Plaintiffs' counsel has stipulated to
the dates contained in the Motion to Amend the Case Scheduling Order.

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JOINT MOTION FOR EXPEDITED

HEARNG - 2
CV-06-327-EFS
#642220 vI /42703-001

Lmv Offces

KARR TUTTLE CAMPBELL
A Professional Service Corporation
1201 Third Avenue, Suile 2900, Seattle. Washington 98101-3028 Telephone [phone], Facsimile [phone]

Case 2:06-cv-00327-EFS

Document 14

Filed 09/13/2007

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DATED this 13th day of

September, 2007.

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KARR TUTTLE CAMPBELL

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Isl Thomas D. Adams Thomas D. Adams, WSBA #18470 E-mail: tadams~karruttle.com Celeste M. Monroe, WSBA #35843 E-mail: cmonroe~karruttle.com Attorney for Defendant North Central Regional Library District KARR TUTTLE CAMPBELL 1201 Third Avenue, Suite 2900 Seattle, Washington 98101 Telephone: [phone] Facsimile: 206.682.7100

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CERTIFICA TE OF SERVICE

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1 hereby certify that on September 13, 2007, 1 electronically fied the foregoing with the Clerk of the

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Court using the cM/EcF system which will send notification of such fiing to the persons listed below:

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Duncan Manvile

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Rafel Manvile PLLc
999 Third Ave., Ste. 1600 Seattle, W A 98104

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KARR TUTTLE CAMPBELL

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BY~tC
Heather L. White

hwhite~karruttie.com

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JOINT MOTION FOR EXPEDITED HEARNG - 3
CV -06-327 - EFS
#642220 vi /42703-001

Lmv Offces

KARR TUTTLE CAMPBELL
A Professional Service Corporation
1201 Third Avenue, Suite 2900, Seattle, Washington 98iOi~J028 Telephone [phone], Facsimile [phone]