Plaintiff's Motion for Enlargement of Time Within Which to Complete Discover

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IN THE UNITED STATES DISTRICT COURT 
FOR THE WESTERN DISTRICT OF TENNESSEE

CLEAMTEE GAR^TER,
Plaintiff,

vs. .CIVIL ACTION 
No. C-75-145

MEMPHIS POLICE DEPARTMENT, et al. ,
Defendants.

PLAINTIFF'S MOTION FOR ENLARGEMENT 
OF TIME WITHIN WHICH TO COMPLETE 

DISCOVERY

Plaintiff, Cleamtee Garner, by and through his undersigned 
attorneys, hereby moves this Court pursuant to Rule 6(b) F.R.C.P. 
to enlarge the time within which discovery must be completed 
from January 15, 1976, the date presently fixed for such pur­
poses, for an additional thirty (30) days. In support of this 
motion, plaintiff would indicate to the Court as follows:

1. Plaintiff served interrogatories upon defendants Hymon, 
Hubbard and Chandler in October, 1975;

2. Defendants Hymon and Chandler responded to plaintiff's 
interrogatories in November, 1975;

3. Defendant Hubbard responded to plaintiff's interrogatories 
during the last week of December, 1975;

4. Plaintiff served upon defendants a request for production 
of documents in October, 1975;

5. Defendants filed a response and objection to plaintiff's 
request in November, 1975;

6. Plaintiff conducted a very close analysis of defendant's 
responses to interrogatories and has determined that



JACK GREENBERG 
CHARLES STEPHEN RALSTON 
DREW S. DAYS, III 

10 Columbus Circle 
New York, New York 10019

WALTER LEE BAILEY, JR. 
D'ARMY BAILEY

Suite 901-Tenoke Building 
161 Jefferson Avenue 
Memphis, Tennessee 38103

Attorneys for Plaintiff

certain answers of defendants therein are imcomplete 
and therefore warrant, in plaintiff's estimation, the 
filing of a motion for more complete answers under 
Rule 37(a) (2) and (3) F.R.C.P.;

7. Such a motion for more complete answers to interrogatories 
is being filed this day by plaintiff;

8. After thorough analysis of defendants' answers to inter­
rogatories, plaintiff is of the position that certain 
documents defendants have refused to provide voluntarily 
are absolutely necessary if plaintiff is going to pre­
pare adequately for trial, and, for that matter, for 
further discovery such as depositions;

9. Based upon that determination, plaintiff is filing this 
day a motion to compel production of documents pursuant 
to Rule 37(a) F.R.C.P. with supporting memorandum.

For the foregoing reasons, plaintiff respectfully submits 
that an enlargement of time within which to complete discovery is 
in the interest of justice, necessary to effective preparation of 
the plaintiff's case and in no way prejudicial to the defendants 
and prays that such enlargement be granted by this Court.

Respectfully submitted.

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CERTIFICATE OF SERVICE

This is.to certify that on this day of January, 1976,
I served a copy of the foregoing "Plaintiff's Motion for 
Enlargement of Time" upon counsel for defendants Henry L. Klein, 
Esq., City of Memphis - Suite 3500, 100 North Main Building, 
Memphis, Tennessee 38103, by placing same in the United States 
mail, postage prepaid.

Attorney for Plaintiff

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