On August 02, 2021 a
Order
was filed
involving a dispute between
and
for OTHER CIVIL
in the District Court of Franklin County.
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Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Jan 10 12:35 PM-21CV004885
0G220 - E2
IN THE COURT OF COMMON PLEAS
FRANKLIN COUNTY, OHIO
CIVIL DIVISION
1415 SOUTHSIDE PROPERTIES, LLC, Case No. 21 CV 4885
Plaintiff, Judge Hawkins
Vv
ERIE INSURANCE COMPANY,
Defendant.
AGREED MOTION TO EXTEND DISCOVERY DEADLINE
Plaintiff 1415 Southside Properties, LLC respectfully moves this Court to extend the
discovery deadline to February 3, 2023. Additional time is needed to complete discovery
Defense counsel’s law office has suffered server issues that have resulted in various depositions
being rescheduled to dates after the current deadline. In addition, the parties are awaiting the
entry of a proposed protective order, so that additional documents may be produced pursuant to
that protective order.
Defendant, Erie Insurance Company, has agreed to the requested extension.
Accordingly, the parties request that the discovery deadline be extended up to and
including February 3, 2023.
A proposed agreed order is being submitted herewith
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Jan 10 12:35 PM-21CV004885
0G220 - E3
/s/ Geoffrey J. Moul
Geoffrey J. Moul (0070663)
Joseph F. Murray (0063373)
James B. Hadden (0059315)
Murray Murphy Moul + Basil LLP
1114 Dublin Road
Columbus, OH 43215
Telephone: 614.488.0400
Facsimile 614 488.0401
E-mail :meul@mmimb.com
m nh rab.com
TL GIT
Counsel for Plaintiff
CERTIFICATE OF SERVICE
Thereby certify that on January 10, 2023, I electronically filed the foregoing with the
Clerk of the Court by using the e-Filing system, which will send a notice of electronic filing to
the following
Gordon D. Arnold Bartholomew T. Freeze
FREUND, FREEZE & ARNOLD FREUND, FREEZE & ARNOLD
1800 Fifth Third Center 65 East State Street, Suite 800
1S. Main St Columbus, OH 43215
Dayton, OH 45402-2017 birceze@ffalaw.com
garnold@ffalaw.com
/s/ Geoffrey J. Moul
Geoffrey J. Moul
Document Filed Date
January 10, 2023
Case Filing Date
August 02, 2021
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Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Jan 10 12:35 PM-21CV004885 0G220 - E2 IN THE COURT OF COMMON PLEAS FRANKLIN COUNTY, OHIO CIVIL DIVISION 1415 SOUTHSIDE PROPERTIES, LLC, Case No. 21 CV 4885 Plaintiff, Judge Hawkins Vv ERIE INSURANCE COMPANY, Defendant. AGREED MOTION TO EXTEND DISCOVERY DEADLINE Plaintiff 1415 Southside Properties, LLC respectfully moves this Court to extend the discovery deadline to February 3, 2023. Additional time is needed to complete discovery Defense counsel’s law office has suffered server issues that have resulted in various depositions being rescheduled to dates after the current deadline. In addition, the parties are awaiting the entry of a proposed protective order, so that additional documents may be produced pursuant to that protective order. Defendant, Erie Insurance Company, has agreed to the requested extension. Accordingly, the parties request that the discovery deadline be extended up to and including February 3, 2023. A proposed agreed order is being submitted herewith Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Jan 10 12:35 PM-21CV004885 0G220 - E3 /s/ Geoffrey J. Moul Geoffrey J. Moul (0070663) Joseph F. Murray (0063373) James B. Hadden (0059315) Murray Murphy Moul + Basil LLP 1114 Dublin Road Columbus, OH 43215 Telephone: 614.488.0400 Facsimile 614 488.0401 E-mail :meul@mmimb.com m nh rab.com TL GIT Counsel for Plaintiff CERTIFICATE OF SERVICE Thereby certify that on January 10, 2023, I electronically filed the foregoing with the Clerk of the Court by using the e-Filing system, which will send a notice of electronic filing to the following Gordon D. Arnold Bartholomew T. Freeze FREUND, FREEZE & ARNOLD FREUND, FREEZE & ARNOLD 1800 Fifth Third Center 65 East State Street, Suite 800 1S. Main St Columbus, OH 43215 Dayton, OH 45402-2017 birceze@ffalaw.com garnold@ffalaw.com /s/ Geoffrey J. Moul Geoffrey J. Moul