Bradburn et al v. North Central Regional Library District

Filing 67

Joint MOTION for Extension of Time to File Joint Statement of Uncontroverted Facts by North Central Regional Library District. (Attachments: # 1 Text of Proposed Order)(Adams, Thomas)

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Bradburn et al v. North Central Regional Library District Doc. 67 1 The Honorable Edward F. Shea Thomas D. Adams 2 3 Celeste Mountain Monroe 4 KA TUTTLE CAMPBELL 5 1201 Third Avenue, Suite 2900 Seattle, Washington 98101-3028 6 (206) 223-1313 7 Attorneys for North Central Regional Library District 8 9 10 11 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON AT SPOKANE 12 13 SARAH BRABUR, PEARL CHERRNGTON, CHARLES HEINEN, and THE SECOND 14 15 AMENDMENT FOUNATION, Plaintiffs, v. 16 17 18 19 20 21 NORTH CENTRAL REGIONAL LIBRARY DISTRICT, ) ) ) NO. CV-06-327-EFS ) ) JOINT MOTION FOR EXTENSION ) OF TIME TO FILE JOINT ) STATEMENT OF ) UNCONTROVERTED FACTS ) ) Noted: March 12,2008 Without Oral ) ) Argument Defendant. 22 23 ) ) 24 25 Plaintiffs Bradburn, Cherrington, Heinlen, and Second Amendment Foundation ("Plaintiffs") and Defendant North Central Regional Library District 26 27 28 JOINT MOTION FOR EXTENSION OF TIME TO FILE JOINT STATEMENT FACTS - i OF UNCONTROVERTED Law Offces cv -06-327-EFS #662528 vI /42703-001 KARR TUTTLE CAMPBELL A Professional Service Corporation 1201 Third Avenue, Suile 2900, SCHUlc, WashiubrjOd 98101-3028 Telepbone (206) 223-1313, Facsimile (206) 682-7100 Dockets.Justia.com 1 ("NCRL") (collectively, "the parties") present this Joint Motion for Extension of 2 3 Time to File Joint Statement of Uncontroverted Facts. The parties agree that this motion may be heard on an expedited basis and without oral argument 4 5 pursuant to LR 7.1(h). 6 7 8 Pursuant to the Scheduling Order (Ct. Rec. 26, pg. 3, Ins. 8-11), the parties were to have filed a Joint Statement of Uncontroverted Facts for 9 10 11 purposes of Fed. R. Civ. Pro. 56(d) three days following service of the reply brief(s) associated with the pending summary judgment motions. With the Court's permission, that deadline was informally extended to March 10,2008. 12 13 14 15 The parties now request a further extension of time to file the Joint Statement of Uncontroverted Facts to March 24. 2008. In support of their request, the parties state: 16 17 18 (a) The summary judgment motions are set for hearing on April 15, 2008. 19 20 21 (b) The parties are working cooperatively, diligently and in good faith toward preparation of a Joint Statement of Uncontroverted Facts in compliance 22 23 24 25 with Fed. R. Civ. Pro. 56(d) and the expectations of this Court. The parties anticipate working in this manner through completion of the task, and have 26 27 28 JOINT MOTION FOR EXTENSION OF TIME TO FILE JOINT STATEMENT OF UNCONTROVERTED FACTS - 2 CV -06-327-EFS #662528 v I /42703-00 I Law Offces KARR TUTTLE CAMPBELL A Professional Service Corpora/ion 1201 Third Avenue, Suile 2900, Seattle, Washin~ion 98101-3028 Telephone (206) 223-1313, Facsimile (206) 682-7100

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