mcmillen files motion for quick discovery

8/14/2019 McMillen files motion for quick Discovery

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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF MISSISSIPI

EASTERN DIVISION

CONSTANCE MCMILLEN,

Plaintiff,

v.

ITAWAMBA COUNTY SCHOOL

DISTRICT; TERESA MCNEECE, in her

official capacity as the Superintendent of

Itawamba County School District; TRAE

WIYGUL, in his official capacity as

Principal of Itawamba Agricultural HighSchool, and RICK MITCHELL, in his

official capacity as Assistant Principal of

Itawamba Agricultural High School,

Defendants.

CIVIL ACTION NO.:1:10-cv-061-D-D

MOTION FOR EXPEDITED DISCOVERY

Plaintiff respectfully requests that this Court order expedited discovery, pursuant to

Rule 26(d) of the Federal Rules of Civil Procedure, and require Defendants to respond to the

attached set of discovery requests, attached hereto as Exhibit A, within seven working days

of the Courts order, or within a time period otherwise designated by the Court.

Defendants do not consent to expedited discovery. Expedited discovery is necessary,

however, to permit the parties to adequately prepare for a requested hearing on Plaintiffs

Motion for Preliminary Injunction, which is filed concurrently.

A brief memorandum in support of Plaintiffs request and a proposed order follow.

THIS the 16th day of March, 2010.

Case 1:10-cv-00061-GHD-JAD Document 6 Filed 03/16/2010 Page 1 of 3


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Respectfully submitted,

/s/ Kristy L. BennettKristy L. Bennett (MS Bar # 99525)

American Civil Liberties Union of Mississippi

P.O. Box 2242Jackson, MS 39225

(601) 354-3408

Fax: (601) [email protected]

Christine P. Sun*American Civil Liberties Union Foundation

125 Broad Street, 18th Floor

New York, NY 10004

(212) 549-2500

Fax: (212) [email protected]

Norman C. Simon*

Joshua Glick*

Kramer Levin Naftalis & Frankel LLP1177 Avenue of the Americas

New York, NY 10036(212) 715-9100

(Fax): (212) 715.8000

[email protected]

[email protected]

*Pro Hac Vice Motion to Follow

Attorneys for Plaintiff



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CERTIFICATE OF SERVICE

I certify that on March 16th, 2010, I filed the foregoing Motion for Expedited

Discovery and accompanying memorandum and exhibits with the Clerk of Court for the

Northern District of Mississippi via the Courts CM/ECF system, which will send notice of

filing to all CM/ECF participants.

Benjamin Griffith

Daniel Griffith

Griffith & Griffith

123 South Court Street

P.O. Drawer 1680Cleveland, MS 38732

COUNSEL FOR THE ITAWAMBA COUNTY SCHOOL DISTRICT

THIS the 16th

day of March, 2010.

/s/ Kristy L. BennettKRISTY L. BENNETT


mcmillen files motion for quick discovery

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