Opinion
Case No. 2-11cv0016
03-29-2012
DORIS HULLETT, individually and as Administratrix of the ESTATE OF JACKIE LEE SNIDER, deceased, Plaintiff, v. DEKALB COUNTY, TENNESSEE; PATRICK RAY, individually and in his official capacity as Sheriff of DeKalb County, Tennessee; KENNETH RAY, individually and in his official capacity; RICK SMITH, individually and in his official capacity; JIM HENDRIX, individually and in his official capacity; MARK NICHOLS, individually and in his official capacity; ERNIE HARGIS, individually and in his official capacity; KYLE CASPER, individually and in his official capacity; JOHN DOES 1-4; RENEE RIDDLE, LPN; ROBERT ALAN STULTZ, PA; and SOUTHERN HEALTH PARTNERS, INC. Defendants.
Sharp/Bryant
Jury Demanded
JOINT RENEWED MOTION TO EXTEND DEADLINES
Comes now the parties and in support of their Joint Renewed Motion to Extend Deadlines state as follows:
1. The parties have resolved calendaring issues among the attorneys, and have set a schedule for deposing the majority of necessary fact witnesses. These depositions will occur on April 10, 11 and 16-18. Additionally, the parties are working together to schedule other fact and FRCP 30(b)(6) witnesses during early May 2012.
2. The experts retained by the plaintiff will need to review transcripts of these depositions, and these transcripts will need to be prepared, and therefore, the parties are requesting to extend the case deadlines by an additional 30 days as set out hereafter. This extension of deadlines will not affect the trial date.
3. The parties request an extension to deadlines as follows:
• Plaintiff Expert Witness Disclosure: May 19, 2012
• Defendants' Expert Witness Disclosure: June 19, 2012
• Completion of all Discovery:July 15, 2012
• Filing of Disposition Motions: August 15, 2012
4. This is the second request of the parties extend the foregoing deadlines. The extension of deadlines requested herein will not require a change in the trial date.
Respectfully Submitted,
Cynthia A. Wilson
Kenneth S. Williams (#10678)
Cynthia A. Wilson (#13145)
Madewell, Jared, Halfacre, Williams & Wilson
230 No. Washington Ave.
Cookeville, Tennessee 38501
[931] 526 - 6101
Counsel for the Plaintiff
_________________
Jennifer Orr Locklin, Esq. (#021575)
Farrar & Bates, L.L.P.
211 Seventh Avenue North
Suite 500
Nashville, Tennessee 37219
(615) 254-3060
Counsel for Defendants DeKalb County, Tennessee, Patrick
Ray, Kenneth Ray, Rick Smith, Jim Hendrix, Mark
Nichols, Ernie Hargis and Kyle Casper