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IN THE UNITED STATES DISTRICT COURT 

FOR THE MIDDLE DISTRICT OF ALABAMA 

SOUTHERN DIVISION 

DEBRA BEYAH, 

Plaintiff, 

v. 

WAL-MART STORES EAST, L.P., 

Defendant. 

CIVIL ACTION NO. 1:06-CV-659 CSC 

JURY DEMANDED 

JOINT MOTION FOR ENLARGEMENT OF DISPOSITIVE MOTION DEADLINE 

 Plaintiff, Debra Beyah (“Plaintiff”), and Defendant Wal-Mart Stores East, L.P. 

(“Defendant”), jointly and respectfully move the Court for a 14-day extension of time, through and 

including July 30, 2007, to file dispositive motions. In support of this motion, the parties 

respectfully show the Court as follows: 

1. 

 Pursuant to Court Order, the dispositive motion deadline is July 16, 2007 and the discovery 

deadline is September 28, 2007. (Doc. 26.) 

2. 

 After extensive written discovery and conducting several depositions, Plaintiff and 

Defendant voluntarily agreed that mediation would be productive. Therefore, on July 6, 2007, the 

parties engaged in a full day of mediation. Although the parties were unable to reach resolution, 

they were able to make significant progress, and they agreed to continue to actively participate in 

the mediation process. 

Case 1:06-cv-00659-CSC Document 29 Filed 07/09/2007 Page 1 of 4
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3. 

 The parties request that this Court extend the dispositive motion deadline by fourteen 

(14) days, through and including July 30, 2007, so that the parties may continue their settlement 

negotiations, without incurring additional legal fees and expenses, which may hinder settlement 

negotiations. The parties are not requesting an extension of the September 28, 2007 discovery 

deadline, or the present trial date set for October 1, 2007. 

4. 

 The parties do not anticipate that any further extensions will be necessary. 

5. 

 Counsel for Plaintiff has reviewed this Motion and has given Defendant permission to 

submit her electronic signature hereon. 

 WHEREFORE, the parties jointly and respectfully request that the Court grant a 14-day 

extension of time, through and including July 30, 2007, for the parties to file dispositive motions 

in the above-referenced case. 

 This 9th day of July 2007. 

s/ Charlotte K. McClusky, Esq.

 Charlotte K. McClusky 

ASB-5296A57M 

 LITTLER MENDELSON 

A Professional Corporation 

 3348 Peachtree Road, NE 

 Suite 1100 

 Atlanta, GA 30326-1008 

 Telephone: (404) 233-0330 

 Facsimile: (404) 233-2361 

 Email: cmcclusky@littler.com

 ATTORNEY FOR DEFENDANT 

 

Case 1:06-cv-00659-CSC Document 29 Filed 07/09/2007 Page 2 of 4
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s/ Ann C. Robertson, Esq.

 Ann C. Robertson 

Temple D. Trueblood 

 Wiggins, Childs, Quinn & Pantazis, LLC 

The Kress Building 

301 19th Street North 

 Birmingham, Alabama 35203 

 Telephone: (205) 314-0500 

 Facsimile: (205) 254-1500 

 Email: arobertson@wcqp.com

 ATTORNEYS FOR PLAINTIFF 

Case 1:06-cv-00659-CSC Document 29 Filed 07/09/2007 Page 3 of 4
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IN THE UNITED STATES DISTRICT COURT 

FOR THE MIDDLE DISTRICT OF ALABAMA 

SOUTHERN DIVISION 

DEBRA BEYAH, 

Plaintiff, 

v. 

WAL-MART STORES EAST, L.P. 

Defendant. 

CIVIL ACTION NO. 1:06-CV-659 

JURY DEMANDED 

CERTIFICATE OF SERVICE 

I hereby certify that on July 9, 2007, I electronically filed the foregoing Joint Motion For 

Enlargement Of Dispositive Motion Deadline with the Clerk of the Court using the CM/ECF 

system which will provide notice to the following: Ann C. Robertson, Temple D. Trueblood, and 

Bobbie S. Crook. 

s/ Charlotte K. McClusky, Esq.

ASB-5296A57M 

LITTLER MENDELSON, P.C. 

3348 Peachtree Road, NE 

Suite 1100 

Atlanta, Georgia 30326-1008 

Telephone: (404) 233-0330 

Facsimile: (404) 233-2361 

E-mail: cmcclusky@littler.com

ATTORNEY FOR DEFENDANT 

Firmwide:82751030.1 015602.4972 

Case 1:06-cv-00659-CSC Document 29 Filed 07/09/2007 Page 4 of 4