UNITED STATES DISTRICT COURT

M IDDLE DISTRICT OF ALABA M A

OFFICE OF THE CLERK

POST OFFICE BOX 711

MONTGOMERY, ALABAMA 36101-0711

DEBRA P. HACKETT, CLERK

TELEPHONE (334) 954-3600

April 9, 2007

NOTICE OF CORRECTION

From: Clerk’s Office

Case Style: Camellia Therapeutic Foster Agency, LLC v. The Alabama Dept of Human

Resources

Case Number: 2:06cv00735-MHT

This Notice of Correction was filed in the referenced case this date to correct the PDF

document previously attached to include the signature on the certificate of service. 

The correct PDF document is attached to this notice for your review. Reference is made to

document # 32 filed on April 6, 2007.

Case 2:06-cv-00735-MHT-CSC Document 34 Filed 04/09/2007 Page 1 of 1
IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF ALABAMA

NORTHERN DIVISION

CAMELLIA THERAPEUTIC )

FOSTER AGENCY, LLC, ETC., )

)

Plaintiff, ) CASE NO.: 2: 06CV735-MHT

)

v. )

)

THE ALABAMA DEPARTMENT OF )

HUMAN RESOURCES, )

)

Defendant.

MOTION FOR EXTENSION OF TIME FOR DISCOVERY

COMES NOW, the Plaintiff, Camellia Therapeutic Foster Agency, LLC, and files

its Motion For Extension of Time For Discovery in the above style manner. As grounds

for this motion the Plaintiff states the follow:

1. Plaintiff filed initial complaint pro se.

2. Plaintiff retained Dwayne L. Brown as counsel per Order of this honorable

Court on 08/18/2006. Attorney Brown filed Notice of Appearance on

09/05/2006.

3. Attorney Brown filed Motion to Withdraw on 02/01/2007, which was granted

on 02/06/2007.

4. Attorney for Defendant, Joel Marsh, filed Motion to Withdraw on 02/20/2007,

which was granted on 02/20/2007.

5. Attorney James Edward Long, counsel for Defendant, filed a Notice of

Appearance on 02/23/2007.

6. Attorneys Kathryn Dickey and Janice Spears-Turk filed a Notice of

Case 2:06-cv-00735-MHT-CSC Document 34-2 Filed 04/09/2007 Page 1 of 3
Appearance on March 13, 2007.

7. All discovery is to be completed by 04/22/2007, per the Scheduling Order

filed 11/15/2006.

8. Attorneys for both parties need additional time to complete discovery, due to

the short period of time that attorneys have been in this case.

9. Plaintiff’s attorney has contacted the Honorable James Edward Long regarding

an extension of time for discovery and he states that he has no objections.

10. The Defendant is not prejudiced by the extension of time.

11. Trial is not set for this cause until October 1, 2007.

12. In the interest of justice, an extension of time for discovery is needed.

Respectfully submitted on this the 6

th day of April 2007.

_/s/__Kathryn Dickey________________

Kathryn Dickey (DIC025)

Attorney for Plaintiff

OF COUNSEL:

KATHRYN DICKEY

Attorney at Law

322 Alabama Street

Montgomery, Alabama 36104

(334) 262-0728

(334) 265-7696 fax

JANICE SPEARS-TURK

Attorney at Law

2735 Office Park Circle

Montgomery, Alabama 36116

(334) 274-0883

(334) 272-3031 fax

Case 2:06-cv-00735-MHT-CSC Document 34-2 Filed 04/09/2007 Page 2 of 3
CERTIFICATE OF SERVICE

I hereby certify that on April 6, 2007, I electronically filed the foregoing with the

Clerk of the Court using the CM/ECF system which will send notification of such filing

to the following:

Honorable James Edward Long

Assistant Attorney General

State of Alabama Department of

Human Resources

Legal Office

P.O. Box 304000

Montgomery, AL 36130-4000

_/s/_Kathryn Dickey__

OF COUNSEL

Case 2:06-cv-00735-MHT-CSC Document 34-2 Filed 04/09/2007 Page 3 of 3