Go To Photographic Evidence
To put this case all on the Record, all Discovery, both Requests and Responses were filed with the Clerk of the Court by the Defendant Pro Se, not just the Certificates of Service.
/construction-lawsuit/
CURRENT CASE DOCKET -  CONTRACT LAWSUIT                    Next Document       Previous Document
IN THE SUPERIOR COURT OF GWINNETT COUNTY
STATE OF GEORGIA

INSULATED WALL SYSTEMS, INC.,               )
Plaintiff,                                                         )
                                                                     )    Civil Action File No.:  
v.                                                                   )     05A06942-9
                                                                     )
RON MCKINNEY,                                           )
Defendant.                                                     )


PLAINTIFF'S BRIEF IN OPPOSITION TO DEFENDANT'S SECOND MOTION TO EXTEND DISCOVERY PERIOD

COMES NOW PLAINTIFF INSULATED WALL SYSTEMS, INC. and in response to Defendant's Second Motion to Extend Discovery Period states as follows:

In June, 2006, this Court had a hearing on all outstanding discovery issues in this case. This case was filed by the Plaintiff in June, 2005 and in the year that followed only some written discovery was propounded by both parties due to objections concerning depositions that had been noticed by both sides.

In the wake of the June 2006 hearing, the Court issued an order extending discovery up and through August 31, 2006.  The Court also clearly stated at the hearing that, in the Courts opinion, enough time had elapsed in this case and that the Court wanted the case moving. In the approximately two months that followed that hearing, the Plaintiff complied with the Courts suggestion and conducted all of the discovery that it intended to take in the case prior to the discovery deadline. Defendant outlined that series of events undertaken by the Plaintiff in his motion to extend the discovery period. While this series of events was somewhat lengthy, it in no way took up every minute of every day of those two months.

In contrast, the Defendant conducted absolutely no further discovery. Other than sending letters concerning the possibility of taking the depositions of a corporate representative and the Plaintiff's duly designated experts, there was no communication from the Defendant indicating the necessity of any further discovery. Those letters stated that he wanted to take those depositions after discovery expired. *1  He also contended that he had to have expert reports prior to deposition the individuals but as the Court is well aware the Civil Practice Act does not require written reports. OCGA 9-11-26. In fact, one of Plaintiff's experts did not issue a report just as it appears that two of the Defendant's did not. *2

*1  Plaintiff has not expressed any objection to such depositions being taken outside of the discovery period so long as they are taken pursuant to the tenets of the Civil Practice Act and at the convenience of the Deponents.

*2  Plaintiff was provided with a letter purporting to be the expert opinion of Macon Gooch who Plaintiff later learned never inspected the property at issue. Nathan Gooch, an employee of Macon Gooch did inspect the property but to date Plaintiff has not received any report authored by him.

Now on the eve of the discovery period's expiration, the Defendant pleads his case and tries to convince the Court that somehow he has been prevented from doing any discovery prior to this time because of something done or withheld by the Plaintiff.  As with all Defendant's arguments there is nothing to support any such thing. Plaintiff has and continues to comply with the Civil Practice Act.  Defendant's practice of law is a pursuit at his own peril. Plaintiff has waited approximately two years to have this matter resolved. This is an obvious attempt to delay by the Defendant. Every day that this case is not decided is another day that the Defendant does not have to pay the Plaintiff. This Court has broad discretion in its granting of additional time for discovery. Amaechi v. Somsino.  Plaintiff respectfully requests that the Court use its discretion to deny Defendant's Motion and have this case proceed at this time. Plaintiff therefore requests that Defendant's Motion be DENIED.

DATED September 1, 2006

IN THE SUPERIOR COURT OF GWINNETT COUNTY
STATE OF GEORGIA

INSULATED WALL SYSTEMS, INC.,               )
Plaintiff,                                                         )
                                                                     )    Civil Action File No.:  
v.                                                                   )     05A06942-9
                                                                     )
RON MCKINNEY,                                           )
Defendant.                                                     )

DEFENDANT'S BRIEF IN REPLY TO PLAINTIFF'S BRIEF IN OPPOSITION TO DEFENDANT'S SECOND MOTION TO EXTEND DISCOVERY PERIOD

COMESNOW DEFENDANT, Ron McKinney, by and through himself, and replies to Plaintiff'sBrief in Opposition to Defendant's Second Motion to Extend Discovery Period andstates the following:            Asnoted by Plaintiff, the list of events in Defendant's Second Motion to ExtendDiscovery Period is quite lengthy and it should be noted by the Court that afull (7) seven out the (9) nine events were instigated by Plaintiff. All ofthese events have required and continue to require an enormous amount time onthe part of Defendant to properly study and prepare a legal response. Inaddition, quiet unlike Plaintiff's Counsel who, by her own admission, hasretired to her home and who, by her own admission, has no other cases to dealwith other than Defendant's, this Defendant still has primary responsibilitiesthat cannot and will not take a back seat to Plaintiff's lawsuit. Defendant isand will continue to be the primary care giver for his 94-year-old mother andif the court desires from the Defendant a daily synopsis of what is requiredfor Defendant to fulfill his principle and primary obligations, Defendant willsupply it.            Defendantis well aware that the Civil Practice Act requires no report to be issued byexpert witnesses and Defendant has no issue with this. What Defendant does takeissue with is when a report is issued and Plaintiff lies about its existence,an event that has been fully proven by Defendant. As documented with evidencein Defendant's Brief in Response to Plaintiff Motion for Protective Order andSanctions and Defendant's Supplemental Brief, Plaintiff has possessed ScottBerlyoung's report since July 10, 2006, at 10:47 PM yet Plaintiff throughPlaintiff's Counsel maintained no such report existed until the lie was exposedon or about August 22, 2006 in Defendant's Brief resulting in Plaintiffproviding said report to the Defendant on or about August 27th, 2006.            Saidreport has been filed with the Court under Defendant's Notice of FilingDiscovery received and stamped by the Court on August 31, 2006.            Defendantinvites the Court to review Mr. Berlyoung's report at this time based onPlaintiff's alleging that it has "waited approximately two years to havethis matter resolved" and Plaintiff's alleging that Defendant's actions infiling his Motion for Extension is an "obvious attempt to delay" and"every day that this case is not decided is another day that Defendantdoes not have to pay Plaintiff." Even though Mr. Berlyoung's report isquite superficial, it also supports several contentions made by Defendant suchas "hand rail loose on deck sides" and "windowsunfinished/trimmed at other windows" and "windows unfinished inframing." Even Plaintiff's own expert does not support Plaintiff'scontention in its Complaint that "Plaintiff completed the work as setforth by the contract in a professional and workmanlike manner" andconsidering that Plaintiff now admits that the windows do not contain argon gasand has full knowledge obtained from the property inspection that the seams ofthe house wrap were not taped as ordered by Defendant, the concrete slab doesnot possess a smooth surface as contracted for by Defendant and there are noshutters on the house supplied by Plaintiff as contracted for by Defendant itis highly unlikely that Defendant will ever be ordered to pay Plaintiff. AndDefendant has not even touched on the shoddy state of the work that wasperformed as is well documented in Defendant's Engineering report provided byMacon E. Gooch Building Consultants, Inc. that has been filed with this Court.            Whilethe lack of Mr. Berlyoung's report did not prevent Defendant from going aheadwith a deposition of Scott Berlyoung, Defendant certainly would have beensurprised by the existence of said report at Mr. Berlyoung's deposition andwoefully unprepared to ask pertinent questions concerning that report.            Furthermore,Defendant takes strong objection to Plaintiff's Footnote Number 2 which states,"Plaintiff was provided with a letter purporting to be the expert opinionof Macon Gooch who Plaintiff later learned never inspected the property atissue. Nathan Gooch, an employee of Macon Gooch did inspect the property but todate Plaintiff has not received any report authored by him." Clearly, asDefendant will show, this is nothing more than a sorry attempt by Plaintiff todiscredit the Engineering Report Defendant has filed with this Court and tosomehow accuse Defendant of lying.            Itis a fact that Nathan D. Gooch, Vice President and Chief Technician for MaconE. Gooch III Building Consultant's Inc., inspected the property and preparedthe Engineering Report. It is also a fact that Macon E. Gooch III has notpersonally inspected the property yet it is also a fact that Macon E. Gooch'sIII Professional Engineering stamp is affixed to said report. Defendant showsthe Court and Plaintiff's Counsel why this is acceptable under Georgia Law.            Byway of Ron McKinney's Affidavit Exhibit "A," and Exhibit"B" obtained from the Georgia Secretary of State's web site. Macon E.Gooch III, the individual, and Macon E. Gooch III Building Consultant's Inc.are both listed on the Georgia Secretary of State's web site as being licensedby the State of Georgia as Professional Engineers. Macon E. Gooch III, theindividual, possesses the Prerequisite License Number PE008889 and Macon E.Gooch III Building Consultant's Inc. possesses the Dependant License Number ofPEF002999.            GeorgiaLaw is clear on this subject as O.C.G.A. 43-15-22(b) states in pertinent part: "No plans, specifications, plats, or reportsshall be stamped with the seal of a registrant unless such registrant haspersonally performed the engineering or surveying work involved or when theregistrant has not personally performed the engineering or land surveying workreflected in any plan, specification, plat, or report, such registrant hasaffixed his or her seal thereto only if such document has been prepared by anemployee or employees under the registrants direct supervisory control on adaily basis and after the registrant has thoroughly reviewed the work embodiedin such document and has satisfied himself or herself completely that such workis adequate. "            Furthermore,O.C.G.A. 43-15-22(c) states that "No registrant shall affix his seal toany plan, specification, plat or report unless he has assumed theresponsibility for the accuracy and adequacy of the work involved."            Andfinally O.C.G.A. 43-15-22(d) states that "any registrant who has affixedhis or her seal to any plan, specification, plat or report prepared by anotherperson not under the registrant's direct supervisory control on a daily basis,and without having thoroughly reviewed such work, shall be deemed to havecommitted a fraudulent act of misconduct in the practice of professionalengineering or land surveying."            Defendantdemands that Plaintiff and its counsel put forth evidence that Macon E. GoochIII has committed "a fraudulent act of misconduct in the practice ofprofessional engineering" and if Plaintiff and it's Counsel cannot providesuch evidence this Defendant moves this Court to sanction Plaintiff and itsCounsel for their sorry attempt to discredit and smear the good names of bothMacon E. Gooch III for affixing his stamp and signature to said EngineeringReport and Defendant for presenting said report to this Court forconsideration.            With respect to the requestedextension, Defendant reminds the Court that he is not asking for anything thathe didn't ask for at the June 19, 2006 hearing, which was to extend discoverythrough October 31st, 2006. This date was not arbitrary and in no way was itselected for the purpose of delay. It was selected after a careful review ofthe tasks before Defendant and in anticipation of a flurry of activity fromPlaintiff.  Of course, Defendant couldnot have known the exact nature of Plaintiff's flurry of activity butconsidering that Defendant believes Plaintiff is attempting to bully it's wayto its own successful completion of this case it is not surprising thatPlaintiff and its counsel are pulling out all the stops in their attempt togain advantage over Defendant. This Court has broaddiscretion in its granting of additional time for discovery as Plaintiff citesand considering the fact that a full six months of the discovery time alreadyafforded was spent waiting on the Court to rule on Protective Orders leftpending through no fault of the Defendant the Court should use that discretionin Defendantís favor. Defendant, therefore,respectfully requests that Defendant's Motion for an Extension of Discovery beGRANTED. This _______day of September 2006.

Respectfully submitted, _____________________________ Ron McKinney, Defendant 4083 Red Laurel Way Snellville, GA  30039 770-979-1254

Mrs. Jana Tabor, Attorney for Plaintiff 450 Arborshade Trace, Duluth, GA 30097   770-814-8134 F. Scott Young, Attorney forPlaintiff Barrickman, Allred & Young, LLC, 5775 Glenridge Drive, Building A Suite 100 Atlanta, GA 30328    404-252-2230


CERTIFICATE OF SERVICE

UNDER PENALTY OFPERJURY, I CERTIFY that a true and exact copy of  

DEFENDANT'S BRIEF INREPLY TO PLAINTIFF'S BRIEF IN OPPOSITION TO DEFENDANT'S SECOND MOTION TO EXTENDDISCOVERY PERIOD was served on PlaintiffsAttorney at the address listed below by depositing the same in the UnitedStates Mails, with sufficient postage thereon

this ______ day of September 2006.

_____________________________ Ron McKinney, Defendant 4083 Red Laurel Way Snellville, GA  30039 770-979-1254

Mrs. Jana Tabor, Attorney for Plaintiff 450 Arborshade Trace, Duluth, GA 30097   770-814-8134 F. Scott Young, Attorney forPlaintiff Barrickman, Allred & Young, LLC, 5775 Glenridge Drive, Building A Suite 100 Atlanta, GA 30328    404-252-2230
NOTICE OF FILING ORIGINAL DISCOVERY


Pursuant to Section 29.1 of the Georgia CivilPractice Act (O.C.G.A 9-11-29.1), Defendant, Ron McKinney, hereby files withthe Court the following items of original discovery: 1)      TheAffidavit of Ron McKinney, dated September 5, 2006. Defendant is filing theseoriginal items of discovery for use and consideration with the Discovery Motionpending and at any hearings or trial. This ______ day of September, 2006.                          

Respectfullysubmitted, _____________________________ Ron McKinney, Defendant 4083 Red Laurel Way Snellville, GA  30039 770-979-1254

Mrs. Jana Tabor, Attorney for Plaintiff 450 Arborshade Trace, Duluth, GA 30097  770-814-8134 F. Scott Young, Attorney for Plaintiff Barrickman, Allred & Young, LLC, 5775 Glenridge Drive, Building A Suite 100 Atlanta, GA 30328   404-252-2230
AFFIDAVIT OF RON MCKINNEY   STATE OF GEORGIA COUNTY OF GWINNETT Personally appeared before the undersigned officerauthorized to administer oaths, comes Ron McKinney, who after having been dulysworn, deposes and states: I am over the age of 21 years and I am the Defendant inthis action. I reside at 4083 Red Laurel Way, Snellville, Georgia inGwinnett County. I am of sound mind and body and have personal knowledgeof the matters stated below and that to the best of my knowledge andbelief what is stated is true and I am competent to testify to all thingsstated in this affidavit. I personally went to the State of Georgia Secretary ofState Web Site located at the Internet Address ofhttp://www.sos.state.ga.us/default1024.asp and printed the attachedProfessional Engineering Licensee Information of Macon E. Gooch III, theindividual, and Macon E. Gooch III Building Consultants, Inc. along withthe two Consent Order's that are a matter of Public Record. They areattached to this Affidavit and marked Exhibit "A", Exhibit"B", Exhibit "C" and Exhibit "D." Attached to this Affidavit and marked Exhibit"E", Exhibit "F", Exhibit "G" Exhibit"H" and Exhibit "I" are true and correct copies ofletters and emails I sent to Plaintiffís counsel in attempts to resolvediscovery disputes, schedule depositions, and otherwise get cooperationfrom Mrs. Tabor so that all of the discovery I need could be accomplishedduring the 2 month time allowed by the court. Mrs. Tabor either ignoresevery request made or responds only at the very last minute and she hasstill not complied with a long-standing request for supplementation,production of documents, the photographs and the video.FURTHERAFFIANT SAYETH NOT.

_____________________________ Ron McKinney

Sworn to and subscribed before me this ____ day of ____________ 2006, __________________________ Notary Public My commission expires:










































IN THE SUPERIOR COURT OF GWINNETT COUNTY
STATE OF GEORGIA

INSULATED WALL SYSTEMS, INC.,         )
Plaintiff,                                                   )            
                                                               )            Civil Action File No.:  
v.                                                             )                       05A06942-9
                                                               )
RON MCKINNEY,                                     )
Defendant.                                                )


DEFENDANTíS MOTION TO EXTEND TIME FOR COMPLETION OFDISCOVERY

COMES NOW,Defendant in the above-styled action, and moves this Court for an OrderExtending Discovery in the above-styled case for an additional 6 months, tobegin on May 1, 2006 or following a decision and Order with regard to Motionspending for Protective Orders, pursuant to Uniform Superior Court Rule 5. Insupport of said Motion, the Defendant shows that he is diligently pursuingdiscovery, but through no fault of the Defendantís, at this time there is stilla Motion for Protective Order pending by both parties and, with the exceptionof some written discovery, additional discovery such as complete and fullProduction of Documents, responses to Interrogatories and Admissions,Depositions and a review of the property in question has not been taken as aresult of discovery disputes, regarding which the Defendant plans to fileMotions to Determine Sufficiency and Motions to Compel.  The Defendant shows that a previousextension of discovery was requested by Plaintiff and granted on January 11,2006 extending discovery until May 1, 2006, during which time Plaintiff hasfailed to request any discovery and consequently should not object to thisextension. Furthermore, as aresult of the transfer of this case from Judge Hamil to Judge Davis around themonth of January 2006, and no decision as of this date made on Motions pendingfrom November and December 2005, which the Defendant respectfully hasrequested, discovery has effectively been suspended during the extensiongranted, which will now expire on May 1, 2006. While the Defendant has in factbeen diligently pursuing discovery, he will suffer extreme hardship through nofault of his own by the court not extending discovery while the motions arestill pending. WHEREFORE, theDefendant respectfully requests that this Court grant his Motion and that thetime for completing discovery in this case be extended for a period to begin onMay 1, 2006 and end October 31, 2006 and respectfully requests that the courtmake a decision and Order regarding the pending Motions based on the recordwithout oral arguments or a hearing due to the Plaintiffís failure to pursueits own request for the months that have past. This _______ dayof April, 2006. Respectfullysubmitted,

_____________________________ Ron McKinney, Defendant 4083 Red Laurel Way Snellville, GA  30039 770-979-1254

Copy Sent to: F. Scott Young and Jana Tabor,Attorney for Plaintiff Barrickman, Allred & Young, LLC 5775 Glenridge Drive Building A Suite 100 Atlanta, GA  30328   404-252-2230    

CERTIFICATE OF SERVICE

UNDER PENALTY OFPERJURY, I CERTIFY that a true and exact copy of  

DEFENDANTíS MOTIONTO EXTEND TIME FOR COMPLETION OF DISCOVERY was served on Plaintiffs Attorney at the address listed below bydepositing the same in the United States Mails, with sufficient postage thereon

this ______ day of April 2006.

_____________________________ Ron McKinney, Defendant 4083 Red Laurel Way Snellville, GA  30039 770-979-1254

Sent to: F. Scott Young and JanaTabor, Attorneys for Plaintiff Barrickman, Allred & Young, LLC 5775 Glenridge Drive Building A Suite 100 Atlanta, GA  30328 404-252-2230

IN THE SUPERIOR COURT OF GWINNETT COUNTY
STATE OF GEORGIA

INSULATED WALL SYSTEMS, INC.,         )
Plaintiff,                                                   )            
                                                               )            Civil Action File No.:  
v.                                                             )                       05A06942-9
                                                               )
RON MCKINNEY,                                     )
Defendant.                                                )

ORDER EXTENDING DISCOVERY

It appearing to the Court that theDefendant has requested an extension of time for completion of discovery in theabove entitled action, and it appearing to the court that the parties havediligently pursued pre-trial discovery, but for good cause shown, additionaldiscovery, including Production of Documents, Requests for Interrogatoryresponses and Admissions, the taking of Depositions and a site inspection isneeded; It is hereby ORDERED that the time forthe parties to complete discovery in the above styled action is hereby extendeduntil October 31, 2006. SO ORDERED this ______DAY OF_______________, 2006,

_______________________________ Judge Tom Davis Gwinnett Superior Court

Prepared by: Ron McKinney, Defendant 4083 Red Laurel Way Snellville, GA  30039 770-979-1254

ProposedOrder respectfully submitted.

IN THE SUPERIOR COURT OF GWINNETT COUNTY
STATE OF GEORGIA

INSULATED WALL SYSTEMS, INC.,         )
Plaintiff,                                                   )            
                                                               )            Civil Action File No.:  
v.                                                             )                       05A06942-9
                                                               )
RON MCKINNEY,                                     )
Defendant.                                                )

 

DEFENDANTíS SECOND MOTION TO EXTEND TIME FOR COMPLETION OF DISCOVERY
COMES NOW,Defendant in the above-styled action, pursuant to Uniform Superior Court Rule5.1, and moves this Court for an Order Extending Discovery in the above-styledcase for an additional 2 months, to begin on September 1, 2006 and ending onOctober 31, 2006. In support of saidMotion, the Defendant shows that he is diligently pursuing discovery, butthrough no fault of the Defendantís or Plaintiff's, at this time Defendant hasnot been able to secure all the discovery he is entitled to. On or about July19, 2006 this court extended discovery to September 1, 2006. Since the June 19,2006 hearing the following events have occurred: (1) On July 5,2006 the property inspection of Defendant's residence occurred. (2) On July 27,2006 Defendant was deposed by Plaintiff's counsel. (3) On August 9,2006 Defendant's spouse was deposed by Plaintiff's counsel. (4) On August 14,2006 reconstruction work began on Defendant's residence to include replacementof windows with argon gas and vinyl siding for the twin purpose of replacingdefective work and for the purpose of discovering latent defects ofinstallation that could only be discovered by the removal of the sidingPlaintiff had installed. As expected this process revealed latent defectspreviously unknown to Defendant. This reconstruction was largely completed asof August 19, 2006. Defendant is moving forward to replace the unsafe,substandard and defective deck and slab and that work should be accomplishedshortly. (5) On July 27,2006, Plaintiff filed a Motion for Protective Order and Sanctions requiring aresponse from Defendant on or about August 27, 2006. Defendant filed hisresponse on August 22, 2006. In addition, Defendant filed his own Motion forSevere Sanctions with this Court on August 22, 2006. These motions are pendingbefore the Court. (6) On August 19,2006, Plaintiff filed a Motion to Compel with this Court requiring   Defendant to respond on or about September19, 2006. (7) On August 22,2006, Plaintiff filed Plaintiff's Second Request for Production of Documents toDefendant requiring a response on or about September 22, 2006. (8) On August 22,2006, Plaintiff filed Plaintiff's Second Interrogatories to Defendant requiringa response on or about September 22, 2006. (9) On August 2,August 22, and August 28, 2006, Defendant sent letters to Plaintiff's counselin an attempt to schedule depositions for Plaintiff's two expert witnesses andof Plaintiff. The earliest dates they can be done on are about September 19, 20or 21st. This was necessary since Plaintiff's counsel will be on leave fromSeptember 12, through September 18, 2006 as filed with this court. As can be seen by this synopsis of events,both Plaintiff and Defendant have been diligent in pursuing discovery since theJune 19, 2006 hearing. As of this writingDefendant still has outstanding several Motions he will be filing as well asthe Depositions he has planned for Plaintiff and Plaintiff's expert witnessesin addition to the responses to Plaintiff's flurry of activity here in theclosing days of August. This is a great deal of work that cannot possibly beaccomplished by September 1, 2006 and as a result the Defendant will sufferextreme hardship through no fault of his own by the court not extending discovery.Defendant strongly believes that all of his work can be accomplished by October31st and believes Plaintiff will not object to this extension considering theirown pending Motions and discovery requests. WHEREFORE, theDefendant respectfully requests that this Court grant his Motion and that thetime for completing discovery in this case be extended for a period to begin onSeptember 1, 2006 and end October 31, 2006. This _______ dayof August 2006          

Respectfully submitted, _____________________________ Ron McKinney, Defendant 4083 Red Laurel Way Snellville, GA  30039 770-979-1254

Mrs. Jana Tabor, Attorney for Plaintiff 450 Arborshade Trace, Duluth, GA 30097   770-814-8134 F. Scott Young, Attorney forPlaintiff Barrickman, Allred & Young, LLC, 5775 Glenridge Drive, Building A Suite 100 Atlanta, GA 30328    404-252-2230

IN THE SUPERIOR COURT OF GWINNETT COUNTY
STATE OF GEORGIA

INSULATED WALL SYSTEMS, INC.,         )
Plaintiff,                                                   )            
                                                               )            Civil Action File No.:  
v.                                                             )                       05A06942-9
                                                               )
RON MCKINNEY,                                     )
Defendant.                                                )

 

CERTIFICATE OF SERVICE

UNDER PENALTY OF PERJURY, I CERTIFY that a true and exact copy of  

DEFENDANTíS 2ndMOTION TO EXTEND TIME FOR COMPLETION OF DISCOVERY was served on Plaintiffs Attorney at the address listed below bydepositing the same in the United States Mails, with sufficient postage thereon

this ______ day of August 2006.

_____________________________ Ron McKinney, Defendant 4083 Red Laurel Way Snellville, GA  30039 770-979-1254

Mrs. Jana Tabor, Attorney for Plaintiff 450 Arborshade Trace, Duluth, GA 30097   770-814-8134 F. Scott Young, Attorney forPlaintiff Barrickman, Allred & Young, LLC, 5775 Glenridge Drive, Building A Suite 100 Atlanta, GA 30328    404-252-2230

IN THE SUPERIOR COURT OF GWINNETT COUNTY
STATE OF GEORGIA

INSULATED WALL SYSTEMS, INC.,         )
Plaintiff,                                                   )            
                                                               )            Civil Action File No.:  
v.                                                             )                       05A06942-9
                                                               )
RON MCKINNEY,                                     )
Defendant.                                                )

 

ORDER  EXTENDINGDISCOVERY

It appearing to the Court that theDefendant has requested an extension of time for completion of discovery in theabove entitled action, and it appearing to the court that the parties havediligently pursued pre-trial discovery, but for good cause shown, additionaldiscovery, including Production of Documents, Requests for Interrogatoryresponses and the taking of Depositions is still needed; It is hereby ORDERED that the time forthe parties to complete discovery in the above styled action is hereby extendeduntil October 31, 2006. SO ORDERED this ______DAY OF_______________, 2006,



_______________________________ Judge Tom Davis


Gwinnett Superior Court

Prepared by: Ron McKinney, Defendant 4083 Red Laurel Way Snellville, GA  30039 770-979-1254

ProposedOrder respectfully submitted.






















http://
memb
ers.aol
.com/r
mckin
2146/
Lawsu
it.htm
l,
http://
homet
own.a
ol.co
m/rmc
kin21
46/La
wsuit.
html

 

page created with Easy Designer