07/18/2008 13 MOTION for Extension of Time to Complete Discovery re: File Rule 26 Disclosures by Perihelion Global, Inc.. (McPhillips, Julian) (Entered: 07/18/2008)
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MOTION FOR EXTENSION OF TIME TO FILE RULE 26 DISCLOSURES
COMES NOW the Defendants Perihelion Global, Inc. and John Beebe, by and through their undersigned counsel, and hereby move this Honorable Court for an extension of time to file
Rule 26 disclosures in this case. As grounds therefore, the Defendants show the following:
1. Up until recently, the parties were engaged in a preliminary venue issue dispute, awaiting the court’s ruling to determine if this court or a Florida court would hear the case.
2. The undersigned has long been scheduled to be out of town from July 19 - 28, 2008, and again from August 4-8, 2008.
3. The Defendants in this cause are preparing a major counter-claim to file against the Plaintiff Burr & Forman.
4. The interests of justice so require.
Wherefore, premises considered, the Defendants pray that this Honorable Court will grant an extension of time to file Rule 26 disclosures in this case.
Respectfully submitted,
Perihelion Global, Inc. and
John Beebe,
Defendants/Counter-Plaintiffs
OF COUNSEL: By /s/ Julian McPhillips
McPHILLIPS, SHINBAUM, LLP Julian McPhillips
516 S. Perry St. Attorney for Defendants/Counter-Plaintiffs
Montgomery, AL 36104
(334) 262-1911
CERTIFICATE OF SERVICE
I hereby certify that I have served a copy of the foregoing, via electronic mail through the court, upon Mr. Victor Hayslip, Esq., Burr & Forman, 3400 Wachovia Tower, 420 N. 20th St., Birmingham, AL 35203, on this the 18th day of July, 2008.
/s/ Julian McPhillips
OF COUNSEL |
