GOODWIN v. PENNRIDGE SCHOOL DISTRICT et alRESPONSE in Opposition re MOTION to Continue Trial Date and Trial-Related Disclosures, Briefing, and Filing DeadlinesE.D. Pa.March 29, 2019IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA DARBIANNE GOODWIN Civil Action No: 17-cv-02431-TR PENNRIDGE SCHOOL DISTRICT, et al. ORDER day of , 2019, upon consideration of Plaintiffs Motion to Extend the Trial Date, Pennridge School District, Jacqueline Rattigan and Gina DeBona's response thereto, it is hereby ORDERED and DECREED that Plaintiffs Motion AND NOW, on this is DENIED. v. By: Honorable Timothy Rice Case 2:17-cv-02431-TR Document 128 Filed 03/29/19 Page 1 of 4 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA DARBIANNE GOODWIN Civil Action No: 17-cv-02431-TR PENNRIDGE SCHOOL DISTRICT, et al. DEFENDANTS' MEMORANDUM OF LAW IN OPPOSITION TO PLAINTIFF'S MOTION TO EXTEND THE TRIAL DATE AND TRIAL-RELATED DISCLOSURES, ]§BI_EFING AND FILING DEADLINES Defendants, Pennridge School District, Jacqueline Rattigan and Gina DeBona, oppose Plaintiffs Motion to Extend the Trial Date and Trial-related Disclosures, Briefing and Filing Deadlines in its entirely, for the reasons more fully set forth in their Response to Plaintiffs Motion to Re-open Discovery, which is being filed in conjunction with this Response and is incorporated by reference. Specitically, Defendants are opposed to Plaintiffs Motion because (1) the companion Motion to Re-open Discovery that sewes as the basis for the present Motion is untimely and meritless, (2) the cost of this litigation has already far exceeded what is proportional to the needs of the case, and (3) this litigation as well as Plaintiffs media campaign to portray the individual defendants, as well as others associated with Pennridge School District, as uncaring toward their students has taken an enormous emotional toll and they do not want any further delays in the resolution of this case. As such, Defendants oppose Plaintiffs Motion and request that the current trial date and pre-tr ia l deadlines remain intact . Defendants are fillly prepared to proceed to tr ia l if their dispositive motions are not granted and are strongly opposed to any continuance that would delay the disposition of this matter. v. Case 2:17-cv-02431-TR Document 128 Filed 03/29/19 Page 2 of 4 Respectfully submitted, MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN BY: DATE: 3/29/19 A / / 0 3 4 8 i f a n f a f f a f z e Joseph J. Santarone, Esquire (ID# PA45723) Jane E. Kane, Esquire (ID# PA46585) Kyle M. Heisner, Esquire (ID# PA309733) 2000 Market Street, Suite 2300 Philadelphia, PA 19103 215-575-2600 jjsantarone@mdwcg.com jekane@mdwcg.com kmheisner@mdwcg.com Attorneysfor Defendants 2 Case 2:17-cv-02431-TR Document 128 Filed 03/29/19 Page 3 of 4 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA DARBIANNE GOODWIN Civil Action No: 17-cv-02431-TR PENNRIDGE SCHOOL DISTRICT, et al. CERTIFICATE OF SERVICE I, KYLE M. HEISNER, ESQUIRE, do he reby ce rtify tha t a true and correct copy of Defendants ' Response to Plaintiffs Motion to Extend the Trial Date was electronically filed with the Court on the date set forth below and is available for viewing and downloading from the ECF System. Ali counsel of record were served via electronic notification and/or e-mail. Respectfully submitted, MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN BY: DATE: 3/29/19 Kyle M. Heisner, Esquire (lD# PA309733) 2000 Market Street, Suite 2300 Philadelphia, PA 19103 215-575~2600 kmheisner@mdwcg.com Attorneysfor Defendants v. 3 Case 2:17-cv-02431-TR Document 128 Filed 03/29/19 Page 4 of 4
