IN THE SUPERIOR COURT OF DEKALB COUNTY
STATE OF GEORGIA
JANET D. MCDONALD,
JAMES B. STEGEMAN,
PLAINTIFFS CIVIL ACTION
V FILE NO: 07CV11398-6
GEORGIA POWER COMPANY,
GEORGIA POWER COMPANY FOREST
& RW SERVICES,
DEFENDANTS
BRIEF IN SUPPORT OF PLAINTIFF’S MOTION TO STAY DISCOVERY AND
ALL OTHER PROCESSES PENDING ORDER ON PLAINTIFF’S
MOTION TO STRIKE DEFENDANT’S ANSWERS
In support of Plaintiffs TO STAY DISCOVERY AND ALL OTHER PROCESSES
PENDING ORDER ON PLAINTIFF’S MOTION TO STRIKE DEFENDANT’S
ANSWERS show the following:
1) March 6, 2008 Plaintiffs mailed to this Honorable Court via United States
Postal Service, Priority Mail label #: 0103 8555 7493 6731 1501,
PLAINTIFF’S MOTION and BRIEF IN SUPPORT OF PLAINTIFF’S
MOTION TO STRIKE DEFENDANT’S ANSWERS. According to USPS
tracking information delivery was made March 08, 2008, see attached Exhibit
“A”.
2) March 6, 2008 Plaintiffs mailed to defendants through their attorney via United
States Postal Service, Priority Mail label #: 0103 8555 7493 9876 8787,
PLAINTIFF’S MOTION and BRIEF IN SUPPORT OF PLAINTIFF’S
MOTION TO STRIKE DEFENDANT’S ANSWERS. According to USPS
tracking information delivery was made March 08, 2008, see attached Exhibit
“B”.
3) Plaintiff’s requested, and believed that Defendants had agreed to wait until
after March 30, 2008 before attempting to schedule further Discovery efforts
due to Plaintiff Stegeman having to file an Appeal Brief To The United States
Court of Appeals for The Eleventh Circuit on a separate matter. See Exhibit
“C”
4) Defendants attorney has requested a Leave of Absence for several periods
during April and disregarded any agreement made between Plaintiffs and
Defendants and set up Depositions March 27, 2008. See Exhibit “D”.
CONCLUSION AND PRAYER
Due to the foregoing and the reasons shown by Plaintiff’s Motion and Brief In
Support Of Plaintiff’s Motion To Strike Defendant’s Answers, Plaintiff’s Motion To Stay
Discovery And All Other Process Pending Order On Plaintiff’s Motion To Strike
Defendant’s Answers and Plaintiff’s supporting Brief, Plaintiffs Pray this Honorable
Court will grant their Motion To Stay until such time as this Honorable Court either
Grants or Denied Plaintiff’s Motion To Strike Answers.
As an alternative to Granting Plaintiff’s Motion, Plaintiffs Pray that this Honorable
Court will Order a Hearing To Show Cause Why Their Motion To Strike Defendant’s
Answers and or a Hearing To Show Cause Why this Motion To Stay should be Granted.
For this Honorable Court’s convenience, Plaintiffs have included a Proposed
Order.
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Respectfully Submitted this 20th day of March, 2008,
BY: ___________________________
JANET D. MCDONALD, Pro Se
821 Sheppard Rd
Stone Mountain, GA 30083
(770) 879-8737
BY: ___________________________
JAMES B. STEGEMAN, Pro Se
821 Sheppard Rd
Stone Mountain, GA 30083
(770) 879-8737
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IN THE SUPERIOR COURT OF DEKALB COUNTY
STATE OF GEORGIA
JANET D. MCDONALD,
JAMES B. STEGEMAN,
PLAINTIFFS
CIVIL ACTION
V FILE NO: 07CV11398-6
GEORGIA POWER COMPANY,
GEORGIA POWER COMPANY FOREST
& RW SERVICES,
DEFENDANTS
CERTIFICATE OF SERVICE
I certify that I have this 20th day of March, 2008 served a copy of the within and
foregoing PLAINTIFF’S BRIEF IN SUPPORT OF PLAINTIFF’S MOTION TO STAY
DISCOVERY AND ALL OTHER PROCESSES PENDING ORDER ON PLAINTIFF’S
MOTION TO STRIKE DEFENDANT’S ANSWERS upon Defendants through their
attorney by depositing in the U.S. Mail, first class with adequate postage affixed thereto,
as follows:
Troutman Sanders, LLP
C/o Brian P. Watt
5200 Bank of America Plaza
600 Peachtree Street
Atlanta, GA 30308-2216
___________________________
JANET D. MCDONALD, Pro Se
821 Sheppard Rd
Stone Mountain, GA 30083
(770) 879-8737
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