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IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI SOUTHEAST DIVISION JORDAN BLAIR PLAINTIFF vs. Case No. 1:02CV88CAS BOB WILLS, AKA BOBBY RAY WILLS, AKA W. B. WILLS, BETTY SUE WILLS, SAM GERHARDT, DEBORAH GERHARDT, BO GERHARDT, JULIE GERHARDT, DREW PARRISH, ROBERT O’BRIANT, ROBERT KENNEDY, DBA “MOUNTAIN PARK BOARDING ACADEMY,” and PALM LANE BAPTIST CHURCH, INC. DEFENDANTS PLAINTIFF’S MOTION FOR EXTENSION OF TIME TO FILE EXCERPTS FROM
DEPOSITIONS OF THE BLAIRS Comes now Plaintiff and motion for extension of time to file excerpts
from depositions of the Blairs, and states: 1.
Depositions of Ron, Jannett, Timmy, and Chris
Blair (the Blairs) were recently completed and have not been transcribed.
2.
The depositions of the Blairs were first scheduled
for November 13, 2003. To accommodate the Blairs, the date was moved to the 26th of November 2003.
A pro se motion to quash was filed on the 24th, and responded to
by the Plaintiff. On the 25th the motion to quash was denied by the Honorable Robert Dawson,
District Judge for the United States District Court, Western District of Arkansas. The
Blairs refused to attend the next day. After some further communications, a date in the
latter part of December was agreed upon, and depositions were taken.
3.
Certain portions of these transcripts will show
that Ron and Jannett Blair would not have sent Plaintiff to Mountain Park Boarding Academy
if the facts alleged in the complaint were true, and they had been informed that their son
would have been treated in such a fashion at Mountain Park Boarding Academy, and possibly
some other pertinent material.
4.
Plaintiff prays that the Court grant Plaintiff an
extension of time to allow the submission of such material in opposition to the motions
for summary judgment by the Defendants, up through and including January 16, 2004.
Plaintiff anticipates that this is sufficient time for transcription, and will submit the
material sooner if possible. WHEREFORE, Plaintiff prays that the Court extend the time for filing
excerpts from the Blair depositions up through and including January 16, 2004, and for
such other and further relief as may be appropriate.
CERTIFICATE OF SERVICE I, Oscar Stilley, by my signature above certify that I have this
December 24, 2003 served the defendants with a copy of this pleading electronically by
CM/ECF to: John Oliver, Attorney at law, Oliver, Oliver, & Waltz, PO Box 559, Cape
Girardeau, MO, 63702-0559; and John Briggs, Attorney at law, Brown & James, P.C., 1010
Market Street, 20th Floor, St. Louis MO 63101-2000. |