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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. 502005CA012194XXXXMB AA
RALPH C. SMITH, SR., and ADELE SMITH
as Co-Personal Representatives of the Estate of
RALPH C. SMITH, JR., deceased, and
RALPH C. SMITH, SR., and ADELE SMITH,
Individually,
Plaintiffs,
vs.
OAKWOOD CENTER OF THE PALM
BEACHES, INC., a Florida Corporation,
4
a3
Defendant
q
/
el :n Hd 8- AUH 80
TW
eI
DEFENDANT, OAKWOOD CENTER OF THE PALM BEACHES INC'S
MOTION FOR EXTENSION OF TIME
Defendant, OAKWOOD CENTER OF THE PALM BEACHES, INC., by
and through the undersigned counsel, hereby move this Court for an extension of
time within which to comply with pretrial disclosures including trial exhibits, trial
witnesses, and expert witness disclosures, and would show the Court as follows:
1. The instant action alleges medical malpractice against this
Defendant.
2. Despite the fact that this case has recently been set for trial on this
Court's docket beginning June 23, 2008, numerous depositions have yet to be
taken.
3. This Court's Order Setting Jury Trial and Directing Pretrial and
Mediation Procedures, dated April 24, 2008, requiring pretrial disclosures,
contemplates that discovery of the parties and ancillary witnesses would be
SONNEBORN RUTTER COONEY & KLINGENSMITH P.A.
1545 Centrepark Drive North, P.O. Box 024486, West Palm Beach, Florida 33402-4486 Tel: 561-684-2000
1CASE NO. 502005CA012194XXXXMB AA
completed by this time. As such, this Defendant is not in a position to provide
final versions of their Trial Witness List, Trial Exhibit List, or Trial Expert Witness
List for the trial of this matter.
4. Since this matter is not ready for trial, and each of the parties are
similarly situated with regard to the discovery not yet completed, no additional
prejudice will inure to any party herein by the granting of this Motion for
Extension of Time.
WHEREFORE, Defendant, OAKWOOD CENTER OF THE PALM
BEACHES, INC., respectfully requests this Court enter an Order Granting its
Motion for Extension of Time and require that the parties file final versions of their
pretrial disclosures after discovery has been completed, and such further relief as
this Court may deem appropriate.
| HEREBY CERTIFY that a true copy of the foregoing was sent U.S. Mail
this 7" day of May, 2008, to WILLIAM W. PRICE, ESQUIRE, William W. Price,
P.A., Counsel for Plaintiffs, 320 Fern Street, West Palm Beach, Florida 33401.
SONNEBORN RUTTER COONEY
& KLINGENSMITH P.A.
P.O, Box 024486
Wet Palm Beach, Fl 33402-4486
5 Pees FAX: 561/684-2312
ce
By
F Afles\Smith v Oakwood-555192\MotionsiMt 4.Extension.of.Time.doc.
SONNEBORN RUTTER COONEY & KLINGENSMITH P.A.
1545 Centrepark Drive North, P.O. Box 024486, West Palm Beach, Florida 33402-4486 Tel: 561-684-2000
2
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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502005CA012194XXXXMB AA RALPH C. SMITH, SR., and ADELE SMITH as Co-Personal Representatives of the Estate of RALPH C. SMITH, JR., deceased, and RALPH C. SMITH, SR., and ADELE SMITH, Individually, Plaintiffs, vs. OAKWOOD CENTER OF THE PALM BEACHES, INC., a Florida Corporation, 4 a3 Defendant q / el :n Hd 8- AUH 80 TW eI DEFENDANT, OAKWOOD CENTER OF THE PALM BEACHES INC'S MOTION FOR EXTENSION OF TIME Defendant, OAKWOOD CENTER OF THE PALM BEACHES, INC., by and through the undersigned counsel, hereby move this Court for an extension of time within which to comply with pretrial disclosures including trial exhibits, trial witnesses, and expert witness disclosures, and would show the Court as follows: 1. The instant action alleges medical malpractice against this Defendant. 2. Despite the fact that this case has recently been set for trial on this Court's docket beginning June 23, 2008, numerous depositions have yet to be taken. 3. This Court's Order Setting Jury Trial and Directing Pretrial and Mediation Procedures, dated April 24, 2008, requiring pretrial disclosures, contemplates that discovery of the parties and ancillary witnesses would be SONNEBORN RUTTER COONEY & KLINGENSMITH P.A. 1545 Centrepark Drive North, P.O. Box 024486, West Palm Beach, Florida 33402-4486 Tel: 561-684-2000 1CASE NO. 502005CA012194XXXXMB AA completed by this time. As such, this Defendant is not in a position to provide final versions of their Trial Witness List, Trial Exhibit List, or Trial Expert Witness List for the trial of this matter. 4. Since this matter is not ready for trial, and each of the parties are similarly situated with regard to the discovery not yet completed, no additional prejudice will inure to any party herein by the granting of this Motion for Extension of Time. WHEREFORE, Defendant, OAKWOOD CENTER OF THE PALM BEACHES, INC., respectfully requests this Court enter an Order Granting its Motion for Extension of Time and require that the parties file final versions of their pretrial disclosures after discovery has been completed, and such further relief as this Court may deem appropriate. | HEREBY CERTIFY that a true copy of the foregoing was sent U.S. Mail this 7" day of May, 2008, to WILLIAM W. PRICE, ESQUIRE, William W. Price, P.A., Counsel for Plaintiffs, 320 Fern Street, West Palm Beach, Florida 33401. SONNEBORN RUTTER COONEY & KLINGENSMITH P.A. P.O, Box 024486 Wet Palm Beach, Fl 33402-4486 5 Pees FAX: 561/684-2312 ce By F Afles\Smith v Oakwood-555192\MotionsiMt 4.Extension.of.Time.doc. SONNEBORN RUTTER COONEY & KLINGENSMITH P.A. 1545 Centrepark Drive North, P.O. Box 024486, West Palm Beach, Florida 33402-4486 Tel: 561-684-2000 2