Motion,Ex Parte: TONIA LYNN KNIGHTEN, GUARDIANVs.BAYSIDE GYMNASTICS AND CHEERLEADING INC

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                                Filing   #  65538944       E-Filed     12/18/2017      04:18:35     PM



                      IN  THE CIRCUIT COURT OF THE
                      SIXTH JUDICIAL CIRCUIT IN AND FOR
                      PINELLAS      COUNTY, FLORIDA
                      GENERAL CIVIL DIVISION

                      TONIA LYNN KNIGHTEN,              as Guardian
                      of JASMINE HINCHCLIFF,


                              Plaintiff,
                      v.                        Case No.:   15-003546~CI-19


                      BAYSIDE GYMNASTICS              &
                      CHEERLEADIN G, INCL,

                              Defendant.
                                                                  l



                                             ELAINTIFF AND DEFENDANT’S JOINT MOTION
                                                      TO EXTEND DISCOVERY CUTOFF
                              Plaintiff,  TONIA     LYNN     KNIGHTEN,        as Guardian    of  JASMINE      HINCHCLIFF,        and

                      Defendant,    BAYSIDE       GYMNASTICS          £5  CHEERLEADING,            INC.,   by   and  through    their


                      undersigned    counsels, hereby    move this   Honorable Court to     extend the   date for “Completion     of

                      Discovery" (discovery cutoff) to the      date.of Pre-Trial  Conference.


                              The Court’s Order      Setting Case fiJr July Trial     and Pretrial   Conference    (“Older”)   stated


                      in Paragraphs   '7
                                         and 8  (“Completion of Discovery”)       that discovery is to   be completed within 45

                      days  of the Pre-Trial   Conference    on January 25,    2018,  which   made   the deadline   December     11,


                      2018.   Plaintiff and Defendant conferred and agreed that moving           the discovery   cutoff to January


                      25, 2018   would be beneficial     to the parties.


                              WHEREFORE,          Plaintiff,  TONIA      LYNN     KNIGHTEN,         as  Guardian    of  JASMINE

                      HINCHCLIFF,       and  Defendant,    BAYSIfiE      GYMNASTICS         85 CHEERLEADING,           INC., hereby


                      respectfully requests    the Court   enter the enclosed   proposed    Order  granting   the present Motion,


                      and for such other relief as the Court deemsjust and proper.




                      FL'I'ADMBS




    ***FT  FFTRONTPA] I Y      FIT ED  12 18 2017  04'18'35  PM'  KEN BURKE       CLERK OF THE CIRCUIT COURT             PINELLAS    COUNTY***
                                                                             Dated:   121’1 8/17




                                                                              gawk/9,       Wynne,       9?.

                     R0      lilé'ély,  q'uiré    I                          David I. Wynne, In, Esquire
                     Sal   rI-Iealy,L.  C                                    Law Offices of Scott L. Astrin
                     Attorneys   for Plaintiffs                              Staff Attorneys for   AIG
                     P.0.  Box   1080?                                       Attorney for Defendant
                     St. Petersburg,  FL 33733                               100 N. Tampa Street, Suite 2605
                     Phone:   727 323-5848                                   Tampa, FL 33602
                     FBN:    0173990                                         Phone:   813-218—251 18
                                                                             Bar #: 0326290




                     FLTADMBS