UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF LOUISIANA

Transcription

1 DEFENDANTS MOTION TO JOIN PLAINTIFF S REQUEST FOR STATUS CONFERENCE NOW INTO COURT, through undersigned counsel, come Defendants, the City of Baton Rouge/Parish of East Baton Rouge ( City/Parish ), Carl Dabadie, Jr. ( Dabadie ), Mary Roper ( Roper ), Lisa Freeman ( Freeman ), Patrick Wenneman ( Wenneman ), James Thomas ( Thomas ), and Jane Doe ( Doe ) (collectively Defendants ), who respectfully request that the Court issue an Order, as requested by the Plaintiff Earnest Taylor in his recently filed Motion for Status Conference [Doc. #75], setting a status conference for the purpose of discussing the outstanding issues in the case. The circumstances warranting a conference are more fully set forth in the Memorandum in Support of this Motion, filed concurrently herewith. The parties recently engaged in a meeting to discuss issues relative to the case, and have developed a general plan for moving the matter forward. A status conference would greatly benefit all parties by allowing them to consider the Court s input when determining the appropriate manner by which resolution can be brought to all claims.

2 Respectfully Submitted: BY ATTORNEYS: Gwendolyn K. Brown (#19891) Special Assistant Parish Attorney Coursey Blvd, Suite 205 Baton Rouge, LA (225) Telephone (225) Facsimile

3 CERTIFICATE I hereby certify that a copy of the foregoing Defendants Motion to Join Plaintiff s Request for Status Conference has been served on all counsel record through a Notice of Electronic Filing generated by the Court s CM/ECF system, including those listed below on this 18 th day of September, Terrence J. Donaue, Jr. Christopher D. Glisson McGlynn, Glisson, & Mouton 340 Florida Street Baton Rouge, Louisiana Gwendolyn K. Brown

4 DEFENDANTS MEMORANDUM IN SUPPORT OF MOTION TO JOIN PLAINTIFF S REQUEST FOR STATUS CONFERENCE Plaintiff Earnest Taylor recently filed Motion for Status Conference [Doc. #75]. Subsequent to the filing of the motion, counsel for Plaintiff and counsel for Defendants met to discuss issues relative to the case, and have developed a general plan for moving the matter forward. However, a number of issues exist regarding which it would be most beneficial to evaluate the Court s input in creating a plan for the parties further legal actions. In addition to those issues identified in the Plaintiff s motion, at the recent meeting of counsel for the Plaintiff and counsel for the Defendants, the parties discussed the possibility of setting a settlement conference with the Magistrate Judge to obtain guidelines regarding issues relative to quantum, as such may assist settlement efforts which, if successful, may obviate the need for the upcoming hearing scheduled to determine issues of quantum on the Second Amendment claims. This case is an unpleasant procedural posture given that a default is now in place, and the Defendants wish to avoid any further inconvenience to the Court. Thus, the Defendants join in the Plaintiff s request for a status conference, respectfully submitting that a status conference would greatly benefit all parties by allowing them to consider the Court s input when determining the appropriate manner by which resolution can be brought to all claims.

5 For the reasons appearing above, Defendant respectfully joins in the Plaintiff s request that the Court set a status conference to address the issues identified within the Plaintiff s motion, as well as those herein identified. Respectfully Submitted: BY ATTORNEY: Gwendolyn K. Brown (#19891) Special Assistant Parish Attorney Coursey Blvd, Suite 205 Baton Rouge, LA (225) Telephone (225) Facsimile

6 CERTIFICATE I hereby certify that a copy of the foregoing Defendant s Memorandum in Support of Motion to Join Plaintiff s Request for Status Conference has been served on all counsel record through a Notice of Electronic Filing generated by the Court s CM/ECF system, including those listed below on this 18 th day of September, Terrence J. Donaue, Jr. Christopher D. Glisson McGlynn, Glisson, & Mouton 340 Florida Street Baton Rouge, Louisiana Gwendolyn K. Brown

7 MIDDLE DISTRICT LOUISIANA NO. 3:13-CV-579-BAJ-RLB ORDER Considering Defendants Motion to Join Plaintiff s Motion for Status Conference, the Court finds the relief requested to be justified and GRANTS the Motion. ACCORDINGLY, IT IS HEREBY ORDERED that the Court will hold a status conference in this matter at a.m./p.m. on the day of, 2014, to discuss the issues remaining in this case. Should it become necessary, the Court will issue further instructions to the parties regarding this conference. Baton Rouge, Louisiana, this day of, UNITED STATES DISTRICT JUDGE