Motion,Ex Parte: CJ-2013-31

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IN THE DISTRICT COURT OF CLEVELAND COUNTY

STATE OF OKLAHOMA
STATE OF OKLAHOMA
TYLER VINCENT GULLEDGE, ) CLEVELAND COUNT, SS.
) FILE)
Plaintiff, )
): JAN 06 2014
v. ) Case No, CJ-2013-31
) In The Office of
MARY JO RAINS, ) Court Clerk RHONDA TALL
)
Defendant. )

JOINT MOTION TO EXTEND DEADLINES
AND CONTINUE PRETRIAL CONFERENCE

COME NOW, Plaintiff and Defendant, jointly, and respectfully request this Court extend the
deadlines and continue the current Pretrial Conference set forth in the Court’s Scheduling Order filed
on August 13, 2013 in the above-captioned matter. In support of their motion, the parties would
state as follows:

1. This Court entered its’ original Scheduling Order in the above matter on August 13,
2013. Said Scheduling Order set the original Pretrial Conference for January 13, 2014 Additionally,
the current discovery deadline is also set for January 13, 2014.

2. The undersigned defense counsel was only recently retained and has not yet had an
opportunity to prepare for trial. The undersigned defense counsel filed a Motion to Substitute
Counsel on January 2, 2014. This Motion to Substitute Counsel has not yet been heard by the Court.

4. The undersigned defense counsel has also identified additional discovery activities
which are necessary for preparing their case for trial and which they believe will aid in evaluating
the potential for any settlement.

5. Upon discussion, counsel for both parties agree it would be prudent to extend the

current Scheduling Order deadlines and continue the presently scheduled Pretrial Conference out ofan abundance of caution to ensure the parties have adequate time to complete discovery and prepare
their respective cases for trial.

6. The parties would state this Motion is not being presented for the purpose of delay.
Rather, the parties would respectfully state that extending the deadlines and delaying the Pretrial
Conference would only assist the parties in preparing their respective cases for trial and evaluating
the potential for any settlement.

7. The parties would respectfully request this Court extend all deadlines and continue
the Pretrial Conference in this case forty-five (45) days from the current setting as set forth in the
Court’s August 13, 2013 Scheduling Order in order to allow the parties ample time to complete
discovery and fully prepare their cases for trial.

6. A proposed Order is attached for the Court’s review.

WHEREFORE, Plaintiff and Defendant, jointly, would respectfully request this Court
continue the Pretrial Conference and all deadlines contained within the Court’s Scheduling Order

for the reasons set forth above.

BY:

ichael Woodson, OBA #16347

Stephanie L. Khoury, OBA #22661

Edmonds Cole Law Firm

7 8. Mickey Mantle Drive, 2 Floor

Oklahoma City, OK 73104

Phone: 405/272-0322

Fax: 405/235-4654

E-mail: mwoodson@edmondscole.com
skh ondscole.com

Attorneys for DefendantBY:
F Esquire

CARR & CARR °

1350 Southwest 89" Street
Oklahoma City, Oklahoma 73159
Telephone: (405) 691-1600
Facsimile: (405) 234-2128
Attorney for Plaintiff