UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN, NORTHERN DIVISION

R. L. Ross,

No. 1:14-cv-14122-TLL-PTM

Plaintiff,

Hon. Judge Thomas L. Ludington

v. Mag. Judge Patricia T. Morris

DONALD BACHAND, individually

And In His Capacity As Former

Provost, Member Of The Professional

Practices Committee, President Of

Saginaw Valley State University

(SVSU) and Member of the SVSU

Board of Control (“BOC”); JILL

WETMORE individually And In Her

Capacity As Dean Of The SVSU

College Of Business And Management

And Member Of The Professional

Practices Committee (“PPC”); SHAUN

BANGERT Individually And In Her

Capacity As Faculty Member Of SVSU

And President Of The SVSU Faculty

Association (SVSUFA); ROBERT

LANE, Individually And In His

Capacity As President And PastPresident Of The SVSUFA; DEBORAH

BISHOP Individually And In Her

Capacity As Professor, Review

Committee Chair, And SVSUFA

Official; CHRISTOPHER SURFIELD,

Individually And In His Capacity As

Associate Professor, Review Committee

Chair, And SVSUFA Official;

STEWART FRENCH Individually And

In His Capacity As Professor At SVSU

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And Official On The Executive Board

Of The SVSUFA; SAUN STROBEL In

Her Capacity As The UNI-SERV

Director For The Michigan Education

Association (MEA) For SVSU;

BROOKS BYAM, Individually And In

His Capacity As A Professor At

Saginaw Valley State University;

HONG PARK, Individually And In

His Capacity As Professor At SVSU;

WILLIAM WILLIAMSON

Individually And In His Capacity As

Professor At SVSU; ROBERT TUTTLE

Individually And Professionally In His

Capacity As Professor At SVSU;

MARK MCCARTNEY Individually

And In His Capacity as a Professor at

SVSU; SURENDER REDDY

Individually And In His Capacity As A

Professor And Member Of The SVSU

PPC; DEBORAH HUNTLEY

Individually And In Her Capacity As

Dean, Provost, Vice President Of

Academic Affairs and Member of the

PPC; DAVID ABBS, Individually And

In His Capacity As A Member Of The

BOC; SCOTT CARMONA,

Individually And In His Capacity As A

Member Of The SVSU Board Of

Control; CATHY FERGUSON,

Individually And In Her Capacity As A

Member Of The SVSU Board Of

Control; DAVID GAMEZ,

Individually And In His Capacity As A

Member Of The SVSU Board Of

Control ; ERIC GILBERTSON,

Individually And In His Capacity As

President Of SVSU And A Member Of

The SVSU Board Of Control; JEFFREY

MARTIN, Individually And In Her

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Capacity As A Member Of The SVSU

Board Of Control; JENEE

VELASQUEZ, Individually And In

Her Capacity As A Member Of The

SVSU Board Of Control; LEOLA

WILSON, Individually And In Her

Capacity As A Member Of The SVSU

Board Of Control; JEROME YANTZ,

Individually And In His Capacity As A

Member Of The SVSU Board Of

Control; ERIK TRUMP, Individually

And In His Capacity As A Member Of

The SVSU Professional Practices

Committee (“PPC”); GRETCHEN

OWOCKI, Individually And In Her

Capacity As A Member Of The PPC;

PATRICIA CAVANAUGH,

Individually And In Her Capacity As A

Member Of The PPC; MARCIA

SHANNON, Individually And In Her

Capacity As A Member Of The PPC;

JOHN MOONINGHAM, Individually

And In His Capacity As A Member Of

The PPC; SUSIE EMOND,

Individually And In Her Capacity As A

Member Of The PPC; JOHN DOE

AND JANE DOE Individually And In

Their Capacity As Employees,

Administrators, or otherwise associated

with SVSU or SVSUFA; SAGINAW

VALLEY STATE UNIVERSITY; and

SVSU FACULTY ASSOCIATION;

Defendants.

Rhonda L. Ross, Pro Se Plaintiff

29106 Glencastle Drive

Farmington Hills, MI 48336

Email: rhondaross@g.harvard.edu

Fillipe S. Iorio (P58741)

Kurt W. Kline (P72291)

Kalniz, Iorio & Feldstein, Co., L.P.A.

Attorneys for Defendants (Bangert, 

Bishop, French, Lane, Strobel, Surfield, 

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SVSU FA)

4981 Cascade Road, S.E.

Grand Rapids, MI 49546

Telephone: (616) 940-1911

Facsimile: (616) 940-1942

Email: groffice@kiflaw.com

Jamie Hecht Nisidis (P48969)

Braun, Kendrick, Finkbeiner, PLC

4301 Fashion Square Blvd.

Saginaw, MI 48603

Telephone: (989) 498-2100

Facsimile: (989) 799-4666

Email: jamnis@braunkendrick.com 

DEFENDANT’S MOTION FOR EXTENSION OF TIME TO ANSWER AMENDED 

COMPLAINT

NOW COMES Defendants Bangert, Bishop, Lane, French, Surfield, SVSUFA/MEA and 

Strobel, by and through their attorneys, Kalniz, Iorio & Feldstein, and for their Motion for 

Extension of Time.

Defendants Bangert, Bishop, Lane, French, Surfield, SVSUFA/MEA and Strobel request 

an extension of time until March 18, 2015 to respond to Plaintiff’s First Amended Complaint for 

all the reasons stated in the attached Brief in Support of Plaintiff’s Motion for Extension of Time 

to Answer Amended Complaint.

Respectfully submitted,

KALNIZ, IORIO & FELDSTEIN CO., L.P.A.

Attorneys for Defendants

Dated: February 20, 2015 s/ Fil Iorio

Fillipe S. Iorio (P58741)

Kurt W. Kline (P72291)

4981 Cascade Road, S.E.

Grand Rapids, Michigan 49546

Telephone: (616) 940-1911

groffice@kiflaw.com

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