Gonzales et al v. City of Albuquerque et al

MOTION for Extension of Time to Complete Discovery

D.N.M.December 1, 2009

CH1 11858464.1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO ANTOINETTE GONZALES, CAROLL AUSTIN, SARAH CLOVER, and ANNETTE MORA, and A CLASS OF SIMILARLY SITUATED CITY EMPLOYEES, Plaintiffs, vs. THE CITY OF ALBUQUERQUE, ED ADAMS, Chief Administrative Officer, and ESTHER TENENBAUM, Division Manager, in their individual and official capacities, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 1:09-cv-00520-JB-RLP MOTION TO EXTEND DISCOVERY, MOTION AND TRIAL DATES The Defendants, City of Albuquerque, et al., hereby present this Motion To Extend Discovery, Motion and Trial Dates as set forth below. Plaintiffs do not object to this motion. The new deadlines and dates agreed upon by the parties are as follows: a. All discovery to be completed by February 8, 2010. b. Class and collective action certification motions to be filed by February 15, 2010. c. Plaintiffs may file motions for joinder of additional parties by February 15, 2010. d. Discovery motions to be filed by March 1, 2010. e. Dispositive motions to be filed by March 15, 2010. f. Pretrial conference and pretrial Order deadlines to be set by the Court. g. Trial to be scheduled by the Court on a date after May 3, 2010. Case 1:09-cv-00520-JB-RLP Document 24 Filed 12/01/2009 Page 1 of 3 2 CH1 11858464.1 Respectfully Submitted CITY OF ALBUQUERQUE Robert M. White City Attorney s/Electronically Signed Michael I. Garcia City of Albuquerque Legal Department P.O. Box 2248 One Civil Plaza Albuquerque, New Mexico 87102 Edward W. Bergmann Seyfarth Shaw LLP 131 S. Dearborn Street Chicago, Illinois 60603 312-460-5000 Case 1:09-cv-00520-JB-RLP Document 24 Filed 12/01/2009 Page 2 of 3 3 CH1 11858464.1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO ANTOINETTE GONZALES, CAROLL AUSTIN, SARAH CLOVER, and ANNETTE MORA, and A CLASS OF SIMILARLY SITUATED CITY EMPLOYEES, Plaintiffs, vs. THE CITY OF ALBUQUERQUE, ED ADAMS, Chief Administrative Officer, and ESTHER TENENBAUM, Division Manager, in their individual and official capacities, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 1:09-cv-00520-JB-RLP CERTIFICATE OF SERVICE I hereby certify that the Defendants’ Agreed Motion to Extend Discovery, Motion and Trial Dates were electronically mailed to counsel of record on the 1st day of December, 2009, along with a copy of this Certificate of Service. Paul Livingston Attorney for Plaintiffs P.O. Box 250 Placitas, NM 87043 s/Electronically Signed Michael I. Garcia, Assistant City Attorney Case 1:09-cv-00520-JB-RLP Document 24 Filed 12/01/2009 Page 3 of 3