Opinion
No. 3:11-cv-0725
02-14-2012
CONNIE TERRELL, Plaintiff, v. ASURION INSURANCE SERVICES, INC. Defendant.
Respectfully submitted, BASS BERRY & SIMS, PLC Alonda W. McCutcheon (# 022350) L. Lymari Cromwell (BPR #027405) Bass, Berry & Sims PLC Attorneys for Defendant Stephen W. Grace (BPR #14867) Attorney for Plaintiff
JUDGE HAYNES JURY DEMAND
JOINT MOTION TO EXTEND DISCOVERY DEADLINE
The parties move the Court to extend the current discovery deadline of February 28, 2012 to the close of business on March 30, 2012. The parties, despite their best efforts will be unable to complete discovery by the current deadline due to scheduling conflicts. The parties have exchanged voluminous written discovery documents and are in the process of scheduling the Plaintiffs deposition as well as the Defendant's Rule 30(b)(6) deposition.
The parties also move the Court to extend the deadline to file all discovery-related statements and/or supplements to expert reports from March 15, 2012 to April 16, 2012. The extension of these deadlines will not affect the remaining deadlines in the Case Management Order for the filing of a dispositive motion or the trial date.
Respectfully submitted,
BASS BERRY & SIMS, PLC
______________________
Alonda W. McCutcheon (# 022350)
L. Lymari Cromwell (BPR #027405)
Bass, Berry & Sims PLC
Attorneys for Defendant
______________________
Stephen W. Grace (BPR #14867)
Attorney for Plaintiff