There was a problem locating the requested document.
Page 1
10/29/19Gask 1498-c2OG8BABHY Document 48t FHea HOT O99 Page 1 of FAGE 82 . om i e ie te r) | ik: i i:
. A eae iN i W t THEY . FILED IN THE U.S. DISTRICT COURT FOR THE DISTRICT OF MARBIGANIDURT . oSTRICT OF MARYLANB CHRISSANN FREEMAN, Do .
129 P 33
Plaintiff, inh OF v. : CIVIL ACTION NO AY-Ba-oBgsORE : JUDGE GRIMM pe pUTY RICHARD SCHOINTUCH, et al., : BY s 4 ne FI FD ENTERt Defendants. : ee ULLED RECENV NOV 4 1999 JOINT MOTION TO EXTEND DISCOVERY AND DISPOSITIVE MOTIONS DEADLINES OBS BPI ey gpuet DEPUT COME NOW defendants, Gipe Associates, Inc. and Boblin, Cywinski & Jackson, by counsel, Lee & McShane, PC, and plaintiff, Chnissann Freeman, by counsel, H. Robert Erwin, Jr., Esquire, and pursuant to Fed. Rule Civ. Proc. 6(b) and Local Rule 105.9 jointly request this Court to move the discovery deadline to January 31, 2000 and the dispositive motions deadline to February 15, 1999 on the grounds that:
1. According to the current Second Amended Scheduling Order, the current discovery deadline closes on October 29, 1999. The current deadline for dispositive motions is November 1, 1999.
2. This case has not progressed as rapidly as originally anticipated due to some recent issues involving a defense motion to compel further deposition testimony of Dr. Ziem and a defense motion to compe] challenge testing of the plaintiff,
3. The parties are currently attempting to schedule the remaining expert depositions on both sides,
4. To accommodate the schedules of counsel and the experts and to allow sufficient preparation time to take their depositions, counsel believes that a ninety day extension of the Al O&K Wed.
/ ae ne fH wy OOF
Page 2
19/28/1999298 :4:98-ceMeSEBatHY Document 48 “Preece Page 2 of BASE 83
discovery and dispositive motions deadlines is realistic,
5. Both parties request this Court to move the current deadlines. WHEREFORE, the defendants and plaintiff, by counsel, jointly request this Court to move
the discovery deadline to January 31, 2000 and the dispositive motions deadline to February 15,
1999.
Respectfully submutted, The Erwin Law Firm, P.A. LEE & MCSHANE, PC By: By: Sh, Dh “Rébert Erwin, Jr. James F. Lee, Jf., Bar # 10806 8 West Madison Street Brandon M. Gladstone, Bar # 014191 Baltimore, MD 21201 1211 Connecticut Avenue, N.W.
(410) 385-6000 Suite 425 Counsel for Plaintiff Chrissann Freeman Washington, DC 20036
(202) 530-8100
Counsel for defendants Gipe Associates, Inc.
and Bohlin, Cywinski & Jackson
PDF Page 1
PlainSite Cover Page
PDF Page 2
10/29/19Gask 1498-c2OG8BABHY Document 48t FHea HOT O99 Page 1 of FAGE 82
. om
i e ie
te r) | ik: i i:
. A eae iN i
W
t
THEY . FILED
IN THE U.S. DISTRICT COURT FOR THE DISTRICT OF MARBIGANIDURT
. oSTRICT OF MARYLANB
CHRISSANN FREEMAN, Do .
129 P 33
Plaintiff, inh OF
v. : CIVIL ACTION NO AY-Ba-oBgsORE
: JUDGE GRIMM pe pUTY
RICHARD SCHOINTUCH, et al., : BY s 4
ne FI FD ENTERt
Defendants. : ee ULLED RECENV
NOV 4 1999
JOINT MOTION TO EXTEND DISCOVERY AND DISPOSITIVE MOTIONS
DEADLINES OBS BPI ey gpuet
DEPUT
COME NOW defendants, Gipe Associates, Inc. and Boblin, Cywinski & Jackson, by
counsel, Lee & McShane, PC, and plaintiff, Chnissann Freeman, by counsel, H. Robert Erwin, Jr.,
Esquire, and pursuant to Fed. Rule Civ. Proc. 6(b) and Local Rule 105.9 jointly request this Court
to move the discovery deadline to January 31, 2000 and the dispositive motions deadline to
February 15, 1999 on the grounds that:
1. According to the current Second Amended Scheduling Order, the current discovery
deadline closes on October 29, 1999. The current deadline for dispositive motions is November 1,
1999.
2. This case has not progressed as rapidly as originally anticipated due to some recent
issues involving a defense motion to compel further deposition testimony of Dr. Ziem and a
defense motion to compe] challenge testing of the plaintiff,
3. The parties are currently attempting to schedule the remaining expert depositions on both
sides,
4. To accommodate the schedules of counsel and the experts and to allow sufficient
preparation time to take their depositions, counsel believes that a ninety day extension of the
Al O&K Wed.
/
ae ne fH wy OOF
PDF Page 3
19/28/1999298 :4:98-ceMeSEBatHY Document 48 “Preece Page 2 of BASE 83
discovery and dispositive motions deadlines is realistic,
5. Both parties request this Court to move the current deadlines.
WHEREFORE, the defendants and plaintiff, by counsel, jointly request this Court to move
the discovery deadline to January 31, 2000 and the dispositive motions deadline to February 15,
1999.
Respectfully submutted,
The Erwin Law Firm, P.A. LEE & MCSHANE, PC
By: By: Sh, Dh
“Rébert Erwin, Jr. James F. Lee, Jf., Bar # 10806
8 West Madison Street Brandon M. Gladstone, Bar # 014191
Baltimore, MD 21201 1211 Connecticut Avenue, N.W.
(410) 385-6000 Suite 425
Counsel for Plaintiff Chrissann Freeman Washington, DC 20036
(202) 530-8100
Counsel for defendants Gipe Associates, Inc.
and Bohlin, Cywinski & Jackson
Third party AI contribution in government documents
Possible
Document content is reproduced directly from government sources. Some filings in our database may themselves contain AI-generated content submitted by third parties to government agencies.
Back to 
