IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF FLORIDA

TALLAHASSEE DIVISION

BOBBI BOLTON,

Plaintiff,

vs. CASE NO.: 4:03cv307-RH/WCS

UNITED STATES OF AMERICA and

CORRECTIONS OFFICER JEFFREY

LINTON,

Defendant.

 

MOTION TO ENLARGE TIME FOR DISCOVERY

Defendant, JEFFREY LINTON, by and through the undersigned counsel, hereby

moves this Court for an enlargement of the time allowed within which to conduct discovery

in the captioned matter and, as cause therefor, states:

1. Defendant retained the undersigned counsel to represent him in defense of this

matter on June 30, 2004.

2. The undersigned counsel has not yet reviewed the Complaint herein, but

anticipates filing a Responsive Pleading. 

3. The undersigned counsel has reviewed a copy the Order Extending Deadline

for Service of Process [DOC. 22], entered May 18, 2004, and the Civil Docket, including the
2

Pre-trial Order [DOC. 23], which indicates a Trial date of September 7, 2004 and Pre-Trial

Conference date of August 13, 2004

4 Discovery is scheduled to close this date, June 30, 2004.

5. The undersigned counsel anticipates requiring additional time within which

to properly prepare a defense on behalf of the defendant and requests an enlargement of

ninety (90) days within which to conduct discovery.

6. Robert D. Stinson, Attorney for the Co-defendant, United States of America,

has been contacted by the undersigned counsel with regard to the enlargement of time for

discovery and he does not object to this Motion. 

7. James V. Cook, Attorney for Plaintiff, left a telephone message on the

undersigned counsel’s voice mail stating that he will be out of town for ten days, or until July

10, 2004. The undersigned counsel has attempted to return Attorney Cook’s telephone call

and although the undersigned counsel has left a telephone message for AttorneyCook on his

mobile telephone, Attorney Cook has not yet returned the call with regard to this motion.

8. The undersigned counsel for Defendant Linton, anticipates an attorney

planning conference with James V. Cook and Robert D. Stinson, to allow the parties to work

out a proposed, amended discovery and trial schedule for submission to the Court for review.

WHEREFORE, Counsel for Defendant, Jeffrey Linton, respectfully requests this

Honorable Court enlarge the time within which to conduct discovery herein for an additional

ninety (90) days, or for a period as agreed upon by the parties in the Amended Report of

Attorney PlanningConference, or as agreed upon by the parties after approved by this Court.
3

I HEREBY CERTIFY that a true and correct copy of the foregoing Motion for

Enlargement of Time for Discovery has been furnished by U.S. Mail/FAX

Transmission/Hand Delivery to James Vernon Cook, Attorney for Plaintiff, Law Office of

James V. Cook, 314 W. Jefferson St., P.O. Box 10021 [32302], Tallahassee, FL 32301-1608,

FAX No. (850) 561-0836, and to Robert Del Stinson, Assistant U.S. Attorney, Attorney for

Defendant USA, Office of the U.S. Attorney, Northern District of Florida, 111 N. Adams St.,

4 Flr., Tallahassee, FL 32301, FAX No. (850) 942-8448, this 30 day of June 2004. th th

Respectfully submitted, 

/s Gary Lee Printy 

GARY LEE PRINTY 

FL BAR NO. 363014 

THE LAW OFFICE OF GARY LEE PRINTY

1804 Miccosukee Commons Dr., Suite 200 

Tallahassee, Florida 32308-5471

Telephone: (850) 877-7299 

FAX: (850) 877-2211

ATTORNEY FOR DEFENDANT

JEFFREY LINTON