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, 519:968 _
~ ~ IN 'TN~ CIRCUIT COIIRT OF THE
NINETF.~N'fH JUDICIAL CIRCUIT~
ST. I.UCIE COUN'PY. FI,ORIDA
CASE N0. 80-19-CA
KAY AHRENS.
Plaintiff,
vs.
KRALHINKLE PHOTOGRAPHY GROUP.
INC. , d/b/a JIFFY PHOTO CENTER, ~ ~=`' ~ t_
Defendant. ~- -
/ ~~
MOTION AND STIPULATZON FOR CONTINUANCE `'~
COMES NOW, the Defendant, KRALHINKLE PHOTOGRAPHY GROUP, INC.,
d/b/a JIFFY PHOTO CENTER, and moves the Court for entry of an Order
continuing the pre-trial conference and trial in this cause of action
pursuant to Florida Rules of Civil Procedure 1.460 until renoticed for
tr ial, and for grounds therefore would state as follows:
1. That counsel of record for the Defendant herein, Jon E.
Johnson of the undersigned law firm, will be unavailable for trial due
to a conflict of trial dockets in that both counsel familiar with this
case are trying,the case of Heather L. Diggett, a minor. etc, Plaintiffs,
vs. Quinones, M.D., et al, Case No. 78-3297 before the Hon. Tom tJaddell,
Jr_ of the Circuit Court,~Eighteenth Juidici~l Circuit in Brevard County,
F~orida. This malpractice case had been set for a time certain as No. Z
on the docket (January 19, 1981) prior to the setting of the present
case and is expected to take at least ten (10) days to try.
2. That additional discovery is necessary in this cause ta fur-
ther protect the interests of both parties.
Dated: January 12, 1981
S*~AI,BEIN, EUBAIJK, JON:~SON,~
ROSIEA--~BUSSEY, P. A.
by ~ .. .; -~..~ ~i"~ ~~'f ~; ~ ` ,_ : ~
12~ eraT~iig~way -`--
P. O. ox 695
P.ockledge, F1 32955
Attorneys for Defendant
305-b36-9600 .
STIPULATIO:J AND COtiSENT
I HEREBY stipulate and agree to the continuance of the above pre-
trial conference and trial of this_cause of action as set forth above.
Dated: , 1981 ~ ` ''
~ k'ALTER . ` COLBATH , Jr . ~~ '
. Attorney for Plaintiff
Suite 300-B.1551. Forum Place
~.'est Palm Beach,Fl 33401
~ nx~~ ~~ 305-686-3337
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