The opinion of the court was delivered by: LEWIS KAPLAN, District Judge
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:
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.
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.
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.
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
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