IN THE UNITED STATES DISTRICT COURT 

FOR THE MIDDLE DISTRICT OF ALABAMA 

EASTERN DIVISION 

ANGELA PRICE, 

 Plaintiff, 

v. 

ROANOKE CITY BOARD OF 

EDUCATION, 

 Defendant. 

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CIVIL ACTION NUMBER: 

3:06-cv-742-VPM 

UNOPPOSED 

MOTION TO EXTEND TIME

TO FILE DISPOSITIVE MOTIONS

AND

EXTEND DEADLINES

Comes now counsel for Defendant in the above-styled case to move 

the Honorable Court to extend the time for the parties to file their dispositive 

motions from August 6, 2007 to August 27, 2007, and to extend all further 

deadlines three weeks; and in support thereof, states: 

Preliminary Statement

The request for a continuance is compelled by the fact that the court 

reporter delivered ten depositions on July 30, 2007, depositions taken June 21 and 

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22. Dispositive motions are due August 6, 2007. The delay in getting all 

depositions necessitates this request. Plaintiff’s counsel does not oppose the 

request. 

1. The deposition of the Plaintiff was taken by Defendant on 

March 21, 2007. 

2. The Plaintiff took depositions of ten employees of the 

Defendant Board of Education on June 21 and 22, 2007. These deponents included 

the Superintendent of the Board; the alleged perpetrator of the alleged sexual 

harassment; and eight employees that Plaintiff named as witnesses of the alleged 

sexual harassment. 

3. The transcripts of the depositions were received late in the day 

July 30, 2007. 

4. Counsel for Defendant has a trial Thursday and Friday, August 

2 through 3, 2007. 

5. Defendant requests an extension to and including August 27, 

2007 to file dispositive motions. 

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6. Because of the delay in receipt of the deposition transcripts of 

the ten employees, the Defendant will be unable to summarize and incorporate the 

ten depositions into its statements of facts. 

7. The parties also request that because of the requested extension 

of three weeks to file dispositive motions that all further deadlines be extended 

three weeks. 

8. Counsel for Plaintiff has no objection to the requested 

extensions of time. 

WHEREFORE, PREMISES CONSIDERED, Defendant respectfully 

moves the Court to extend the dispositive motion deadline to and including August 

27, 2007, and all further deadlines an additional three weeks. 

 s/Donald B. Sweeney, Jr. 

Donald B. Sweeney, Jr. (SWE002) 

OF COUNSEL

Bradley Arant Rose & White LLP

One Federal Place 

1819 Fifth Avenue North 

Birmingham, AL 35203-2104 

Telephone: (205) 521-8000 

Facsimile: (205) 521-8800 

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CERTIFICATE OF SERVICE

I hereby certify that on July 31, 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: 

Adam M. Porter, Esq. 

2301 Morris Avenue, Suite 102 

Birmingham, AL 35203 

and I hereby certify that I have mailed by United States Postal Service the 

document to the following non-CM/ECF participants: 

None 

Respectfully submitted, 

s/ Donald B. Sweeney, Jr. 

Donald B. Sweeney, Jr. (asb-3803-277d)

Bradley Arant Rose & White LLP

One Federal Place 

1819 Fifth Avenue North 

Birmingham, AL 35203-2104 

Telephone: (205) 521-8000 

Facsimile: (205) 521-8800 

E-mail: dsweeney@bradleyarant.com 

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