Document for Indiana Farm Bureau Insurance v. Caleb Link, Sarah Link

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                                Filed: 9/21/2023 9:38 AM
                                                                                                            Clerk
                                                                                           Allen County, Indiana
                                                                                                              ED




STATE OF INDIANA                      )          IN THE ALLEN SUPERIOR COURT
                                      )    SS:
COUNTY OF ALLEN                       )          CAUSE NO. 02D09-2306-PL-000222


 INDIANA FARM BUREAU INSURANCE,                            )
 as Subrogee of Pong Simon,                                )
                                                           )
                  Plaintiff,                               )
                                                           )
           vs.                                             )
                                                           )
 CALEB LINK,                                               )
 SARAH LINK,                                               )
                                                           )
                  Defendant.                               )

           PLAINTIFF’S MOTION TO VACATE CASE MANAGEMENT CONFERENCE

       Plaintiff, by counsel, moves the Court to vacate the Court’s Case Management

Conference set for September 28, 2023, at 11:00 a.m. and in support states:

       1.        Counsel for the Plaintiff is filing, contemporaneously with this response, a

Motion for Default Judgment to further the prosecution of this claim.

       2.        This motion is made in good faith and not for the purposes of delay.

       3.        The Defendant will not be prejudiced if the presently scheduled hearing is

vacated.

       WHEREFORE, the Plaintiff, by counsel, respectfully requests the Court to vacate the

case management conference in this matter presently scheduled for September 28, 2023.

                                              Respectfully submitted,

                                              McNEELY LAW LLP


                                              /s/ Nicholas R. Dismukes
                                              Nicholas R. Dismukes, Attorney No. 31281-49
                                              Attorney for Plaintiff
                                 CERTIFICATE OF SERVICE

       The undersigned hereby certifies that a copy of the foregoing Plaintiff's Motion to Vacate

Case Management Conference has been served upon:

       Caleb Link
       719 Stratton Rd
       Fort Wayne, IN 46825

       Sarah Link
       719 Stratton Rd
       Fort Wayne, IN 46825


by placing the same in the United States Mail, first class, postage prepaid, this 21st day of
September, 2023.

                                              /s/ Nicholas R. Dismukes
                                              Nicholas R. Dismukes


McNEELY LAW LLP
2177 Intelliplex Drive
Suite 202
Shelbyville, IN 46176
Telephone: 317-825-5230
Facsimile: 317-825-5250