Opinion
Master File Number: 00 Civ. 2843 (LAK).
August 8, 2005
MOTION FOR ADDITIONAL TIME
COMES NOW, the Plaintiffs, by and through their counsel, Ken Adcock, Esq., and hereby files this, their Motion for Additional Time, in this action and as grounds therefore, would show unto this Honorable Court the following:
1.
On April 27, 2005, the Court granted Defendant Warner-Lambert, et al.'s Motion for an Order Requiring Plaintiffs to Produce Case-Specific Expert Reports. Pretrial Order No. 370 required Plaintiffs to produce expert reports in three groups based alphabetically on the "surname of the first named plaintiff in each case. The expert reports in which the surname of the First Named Plaintiff begins with the letters A through I shall be served by August 1, 2005.
2.
Counsel for Plaintiffs, Ken Adcock, Esq., recently changed law firms on June 1, 2005. As a result of the subject move, the Plaintiffs' files have been placed in storage and are not readily accessible to Plaintiffs' counsel.
3.
Additionally, Plaintiffs' counsel has been unable to meet with their expert, Dr. Calvin Ramsey, regarding the directives of Pretrial Order No. 370. Plaintiffs' counsel represents the following individuals in which the surname of the First Named Plaintiff begins with the letters A through I: Easter Johnson, Patrick Chaney, Cameron Wright, Sr., Cameron Wright Sr., Jonnie Newell, Shelia Wilson, Neta Stringer, Wavine Campbell, Thomas Duncan, James Eiland, Henry Herring, Edward Hurlbert, Dorothy Pegues, Esther Watkins, and Ora Cox. As such, Plaintiffs will need additional time to adequately comply with Pretrial Order No. 370.
4.
The undersigned counsel requests that the Court grant the Plaintiffs ninety (90) days from August 1, 2005, to submit expert reports for all First Named Plaintiffs in which the First Letter of the surname begins with letters A through I.
WHEREFORE, PREMISES CONSIDERED, Plaintiffs move this Honorable Court to allow them an additional Ninety (90) days from August 1, 2005, to submit expert reports for all First Named Plaintiffs in which the First Letter of the surname begins with letters A through I.
RESPECTFULLY SUBMITTED.