You are on page 1of 2

MIDDLESEX, SS.

COMMONWEALTH OF MASSACHUSETTS SUPERIOR COURT DOCKET NO. 08-04641-B

JOHNSON GOLF MANAGEMENT, INC., PLAINTIFF V. TOWN OF DUXBURY, AND NORTH HILL ADVISORY COMMITTEE, CONSISTING OF MICHAEL DOOLIN, CHAIRMAN, SCOTT WHITCOMB, ROBERT M. MUSTARD, JR., MICHAEL MARLBOROUGH, ANTHONY FLOREANO, MICHAEL T. RUFO, THOMAS K. GARRITY, RICHARD MANNING, W. JAMES FORD, AND GORDON CUSHING (EX OFFICIO) and CALM GOLF, INC., CHARLES LANZETTA DEFENDANTS
AND

JOINT MOTION TO EXTEND DISCOVERY DEADLINE Now come the parties in the above referenced matter and move that the discovery deadline in the above referenced matter be extended to July 31, 2012 to complete the depositions previously scheduled and to take the depositions of witnesses identified in the Joint Pre-Trial Memorandum filed in November 2011. For cause thereof, the parties state that the extension of discovery will facilitate a n orderly trial of this matter which is scheduled to commence on October 1, 2012. The parties and their respective counsel have agreed to the extension of the discovery deadline, and the only objection to the extension is being asserted by a prospective witness, Robert Troy, Esq., who was Duxbury’s Town Counsel during the RFP process from 2008 through 2010. The deposition of Attorney Troy was noticed without objection of any party for April 23, 2012 and it was re-scheduled for June 13, 2012.

The Plaintiff, By its attorneys, Date: June __ 2012 _______________________ Stephen R. Follansbee FOLLANSBEE and McLEOD, LLP 536 Granite Street Braintree, MA 02169 (781) 848-1500 BBO # 173820 _______________________ E. David Edge, Esq. Geary & Associates 161 Summer Street (781) 585-0008 BBO # 655881 _______________________ Leonard Kesten, Esq., Brody, Hardoon, Perkins & Kesten, 1 Exeter Plaza, 12th Floor Boston, MA 02116 E. (617) 880-7100 BBO # __________

_______________________ Robert S. Troy, Esq. Troy Wall Associates 90 Old Kings Highway Sandwich, MA 02563 BBO # __________