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MCCLATCHEY v. ASSOCIATED PRESS - Document No. 11
MCCLATCHEY v. ASSOCIATED PRESS - Document No. 11
11
Case 3:05-cv-00145-TFM Document 11 Filed 12/02/2005 Page 1 of 3
VALENCIA M. MCCLATCHEY
Plaintiff
Civil Action No. OS- 145J
Defendant.
Plaintiff Valencia McClatchey, and Defendant The Associated Press , by and through
their attorneys , hereby submit this Joint Motion for an Extension of Time. In support of the
On July 2S , 2005, this Court entered a Case Management Order and set the
following dates:
Dockets.Justia.com
Case 3:05-cv-00145-TFM Document 11 Filed 12/02/2005 Page 2 of 3
exchanged documents and written discovery. The parties have been attempting to set
deposition dates. However, due to witnesses ' schedules , the parties wil be unable to
Accordingly, the partes jointly seek a 60-day extension of time and an order
WHEREFORE , Plaintiffs and Defendant respectfully request that the Court approve
the 60-day extension of time and enter the revised schedule above.
Respectfully submitted
VALENCIA MCCLATCHEY
ohn E. Hall
ICA/
Eckert Seamans Cherin & Mellott
600 Grant Street , 44th Floor 2 (
Pittsburgh PA 15219
412. 566. 1915
Case 3:05-cv-00145-TFM Document 11 Filed 12/02/2005 Page 3 of 3
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true copy of the foregoing JOINT
MOTION FOR AN EXTENSION OF TIME was served upon the below listed parties on
this 1 day of December , 2005:
Jo Hall
1;L1e I t9