throbber
State Court of Fulton County
`**E-FILED**
`18EV000720
`8/29/2018 10:41 AM
`LeNora Ponzo, Clerk
`Civil Division
`
`STATE COURT OF FULTON COUNTY
`
`STATE OF GEORGIA
`
` CIVIL ACTION FILE NO.
`
` 18EV000720
`
`* *
`
`* *
`
`* *
`
`CHARMTKA A. PLACTDE,
`
`Piaintiff,
`
`vs.
`
`YOLANDRA N. ALEXANDER AND *
`JOHN DOES 1-3,
`
`* *
`
`Defendant.
`
`*
`
`JOINT CONSENT MOTION TO EXTEND THE DISCOVERY PERIOD
`
`The parties in the above-referenced action, by and through counsel, as provided by Uniform
`
`State Court Rule 5.1, hereby mutually request that the time in which they must complete discovery
`
`be extended up through and including December 21, 2018. In support of this motion, the parties
`
`show the following:
`
`The parties have been diligently and cooperatively proceeding with discovery in this
`
`action;
`
`Defendant, as evidenced by the signature of interested counsel on the Motion, does not
`
`object to an extension of the discovery period;
`
`The parties intend to complete discovery in an expeditious manner.
`
`A proposed Order is attached hereto.
`
`THIS_
`
`_DAY OF AUGUST, 2018.
`
`Signatures on Following Page
`
`

`

`P. Charles Scholle
`Bar Number 629736
`Todd Shugart
`Bar Number 190245
`Scholle Law
`6340 Sugarloaf Parkway. Suite 200
`Duluth, Georgia 30097
`770-71 7-5 I 00
`
`44¢» 44m
`
`M&a
`
`W. Curtis Anderson
`(With Express Permission)
`Bar Number 0| 8470
`Downey & Cleveland, LLP
`288 Washington Avenue
`Marietta, GA 30060
`770-422—3233
`
`

`

`STATE COURT OF FULTON COUNTY
`STATE OF GEORGIA
`
`CIVIL ACTION FILE NO.:
`
`18EV000720
`
`* 3
`
`|:
`
`* *
`
`* *
`
`*
`
`* *
`
`*
`
`CHARMIKA A. PLACIDE‘
`
`Plaintiff,
`
`vs.
`YOLANDRA N. ALEXANDER AND
`JOHN DOES 1-3.
`
`Defendant.
`
`CERTIFICATE OF SERVICE
`I, Charles Scholle, hereby certify that I have this day served the foregoing JOINT
`CONSENT MOTION TO EXTEND THE DISCOVERY PERIOD upon the proper party or parties
`by depositing a copy ofsame in the United States Mail having sufficient postage thereon OR via
`Registered Ovemight Delively, addressed as follows:
`W. Curtis Anderson
`Downey & Cleveland, LLP
`288 Washington Avenue
`Marietta, GA 30060
`19'“
`
`THIS
`
`DAYOFM ,2018.
`Mica
`
`Respectfully submitted,
`
`Todd Shugart
`Georgia Bar N0: 190245
`Charles Scholle
`Georgia Bar No: 629736
`Attorneysfor Plaintiff
`
`SCHOLLE LAW
`6340 Sugarloaf Parkway, Suite 200
`Duluth, Georgia 30097
`770-7] 7—5 l 00
`
`

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