AGREED MOTION TO EXTEND EXPERT DEADLINES. Plaintiffs, Gilbert Joe Cisneros, Catherine Garcia Sonnier, Martha Gonzalez,

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1 Case 4:12-cv Document 25 Filed in TXSD on 03/19/13 Page 1 of 4 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION GILBERT JOE CISNEROS, CATHERINE GARCIA SONNIER, MARTHA GONZALEZ, SALVADOR MARTINEZ, EDWARD YBARRA, ARNOLD HURTADO, MELINDA VILLARREAL Plaintiffs vs. Civil Action No. 4:12-cv PASADENA INDEPENDENT SCHOOL DISTRICT; MARSHALL KENDRICK, JERRY ROSS SPEER, NELDA SULLIVAN, VICKIE MORGAN, FRED ROBERTS, MARISELLE QUIJANO-LERMA, AND JACK BAILEY, ALL IN THEIR OFFICIAL CAPACITIES AS MEMBERS OF THE BOARD OF TRUSTEES OF THE PASADENA INDEPENDENT SCHOOL DISTRICT Defendants AGREED MOTION TO EXTEND EXPERT DEADLINES Plaintiffs, Gilbert Joe Cisneros, Catherine Garcia Sonnier, Martha Gonzalez, Salvador Martinez, Edward Ybarra, Arnold Hurtado, and Melinda Villarreal and Defendants, Pasadena Independent School District, Marshall Kendrick, Jerry Ross Speer, Nelda Sullivan, Vickie Morgan, Fred Roberts, Mariselle Quijano-Lema and Jack Bailey, hereby file this Agreed Motion to Extend Expert Deadlines and would show the court as 1

2 Case 4:12-cv Document 25 Filed in TXSD on 03/19/13 Page 2 of 4 follows: 1. This suit involves Plaintiffs attempt to establish single-member districts thereby giving the Latino population a reasonable opportunity to elect candidates of their choice. This lawsuit was filed on August 27, As was detailed at the recent hearing, data collection for the appropriate geographic region has been slow and what data can be located requires entry in electronic form. For these reasons, counsel has agreed on new dates to provide expert disclosures. Such dates will not interfere with the Court's schedule for pre-trial and trial of this matter. 2. All parties to this litigation have agreed to extend the expert deadlines as follows: Deadline for Plaintiffs Expert Disclosure June 17, 2013 Deadline for Defendants Expert Disclosure July 22, 2013 CONCLUSION The parties respectfully request that the Court extend the deadlines as described 2

3 Case 4:12-cv Document 25 Filed in TXSD on 03/19/13 Page 3 of 4 above and in the attached order. Dated this 19th day of March, Respectfully submitted, BRAZIL & DUNN LLP s/ Chad W. Dunn Chad W. Dunn State Bar Number: Federal Bar Number: K. Scott Brazil State Bar Number: Federal Bar Number: Cypress Creek Parkway, Suite 530 Houston, Texas Telephone: (281) Facsimile: (281) Rick Molina State Bar Number: Federal Bar Number: Fuqua, Suite 580 Houston, Texas Telephone: (281) Facsimile: ( Paul Moody Moody Law Firm State Bar Number: Federal Bar Number: Bellaire Boulevard, Suite 214 Houston, Texas Telephone: (713) Facsimile: (713) Attorneys for Plaintiffs 3

4 Case 4:12-cv Document 25 Filed in TXSD on 03/19/13 Page 4 of 4 /s/ C. Robert Heath C. Robert Heath State Bar Number: Federal Bar Number: Bickerstaff Heath Delgado Acosta LLP 3711 South MoPac Expressway Building One, Suite 300 Austin, Texas Telephone: (512) Facsimile: (512) Attorneys for Defendants CERTIFICATE OF SERVICE I hereby certify that on March 19, 2013, I electronically provided this document to the following attorneys of record: C. Robert Heath Bickerstaff Heath Delgado Acosta LLP 3711 South MoPac Expressway Building One, Suite 300 Austin, Texas (Attorneys for Defendants) s/ Chad W. Dunn Chad W. Dunn 4

5 Case 4:12-cv Document 25-1 Filed in TXSD on 03/19/13 Page 1 of 2 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION GILBERT JOE CISNEROS, CATHERINE GARCIA SONNIER, MARTHA GONZALEZ, SALVADOR MARTINEZ, EDWARD YBARRA, ARNOLD HURTADO, MELINDA VILLARREAL Plaintiffs vs. Civil Action No. 4:12-cv PASADENA INDEPENDENT SCHOOL DISTRICT; MARSHALL KENDRICK, JERRY ROSS SPEER, NELDA SULLIVAN, VICKIE MORGAN, FRED ROBERTS, MARISELLE QUIJANO-LERMA, AND JACK BAILEY, ALL IN THEIR OFFICIAL CAPACITIES AS MEMBERS OF THE BOARD OF TRUSTEES OF THE PASADENA INDEPENDENT SCHOOL DISTRICT Defendants ORDER GRANTING AGREED MOTION TO EXTEND EXPERT DEADLINES On this day came on for consideration Plaintiffs, Gilbert Joe Cisneros, Catherine Garcia Sonnier, Martha Gonzalez, Salvador Martinez, Edward Ybarra, Arnold Hurtado, and Melinda Villarreal and Defendants, Pasadena Independent School District, Marshall Kendrick, Jerry Ross Speer, Nelda Sullivan, Vickie Morgan, Fred Roberts, Mariselle Quijano-Lema and Jack Bailey s Agreed Motion to Extend Expert Deadlines and having considered the Motion, the Court is of the opinion that the Motion should be granted. It

6 Case 4:12-cv Document 25-1 Filed in TXSD on 03/19/13 Page 2 of 2 is therefore, Ordered that the following schedule concerning experts shall govern the disposition in this case while all other deadlines adopted in the Court's scheduling order shall remain: Deadline for Plaintiffs Expert Disclosure June 17, 2013 Deadline for Defendants Expert Disclosure July 22, 2013 SIGNED this day of, Keith Ellison United States District Court Judge