IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA
FREEDOM FROM RELIGION FOUNDATION, INC.; DOE 1, by Doe 1's next friend and parent MARIE SCHAUB, who also sues on her own behalf; DOE 2, by Doe 2's next friend and parent DOE 3, who also sues on Doe 3's own behalf, Plaintiffs, vs. NEW KENSINGTON-ARNOLD SCHOOL DISTRICT, Defendant. : : : : : : : : : : : : : : Civil Action No. 12-1319 JURY TRIAL DEMANDED
BRIEF IN SUPPORT OF MOTION TO COMPEL AND FOR LEAVE TO CONDUCT ADDITIONAL DEPOSITIONS, PURSUANT TO F.R.C.P. 30 AND 34
The Defendant, New Kensington-Arnold School District, by and through its attorneys, Anthony G. Sanchez, Esquire, Amie A. Thompson, Esquire, and the law firm of Andrews & Price LLC, files the following Brief in Support of Motion to Compel and for Leave to Conduct Additional Depositions in accordance therewith.
This action was commenced by the filing of a Complaint at the above number. On July 19, 2013, Defendant served Interrogatories and a Request for Production of Documents upon Plaintiffs. (A copy of the transmittal letter is attached as Exhibit “A”.) Plaintiffs responded to Defendant's discovery requests on September 13, 2013, objecting to 16 of the 22 Interrogatories (Nos. 5-8; 10; 11-13; 15-22) and providing partial answers thereto. (A copy of the transmittal letter is attached as Exhibit “B”.) On September 26, 2013, Defense counsel wrote to Plaintiffs’ counsel via E-mail concerning numerous deficiencies the responses. (Exhibit “C”.) Plaintiffs’ 1
Case 2:12-cv-01319-TFM Document 38 Filed 04/21/14 Page 1 of 16