No Value: HUNT HELEN SUE vs. FINEMAN MATTHEW J DPM PA

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                                IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
         IN AND FOR CHARLOTTE COUNTY, FLORIDA

HELEN SUE HUNT
and JOHN HUNT,

          Plaintiffs,

vs.                                                                                  CASE NO. 00-185:CA ~:
                                                                                                                                           ve
                                                                                                                                           ow
PAMELA J. HUMPEL, D.P.M.,                                                                                                       oo
and MATTHEW J. FINEMAN,
D.P.M., P.A.,

          Defendants,




               PLAINTIFFS’ MOTION FOR EXPEDITED DISCOVERY

          Plaintiffs,            HELEN        SUE        HUNT    and    JOHN         HUNT,        Husband         and    Wife,        by

and      through        their        undersigned                counsel,         hereby            move     this        Court        for

Expedited          Discovery,            and        as     grounds         therefore               state     as     follows

          1        That        the     above-referenced                  matter              is    currently            scheduled

 for     Jury      Trial        during        the         two-week         docket            commencing            on     June        3

 2002,         before     the     Honorable               Sherra       Winesett,              Circuit        Judge

           2       That         counsel         for        Defendant             HUMPEL            was      discharged               and

 replaced,         in     January        of    2002,           although         no    notice         of    said     change           has

 been      filed        with     the    Court             to    date

           3        That        Plaintiffs           continued             to    await            receipt     of    the     change

 of      counsel        notice,        before            filing        additional                 pleadings,            including

                                                                                61477887 Dat Charlotte County Clerk
                                                                                              e: tec 13:15:26                         x 00.
                                                                                Case#: 00000

                                                                                     nina”
their        Request               for        Production.               To     date,         no        such     notice                has     been

provided          to      Plaintiffs’                  counsel.

        4           That           Plaintiffs               filed       a Request            for        Production                   of     x-rays

taken        by   the         Defendant,               on    or    about       March         19,        2002,        which            evidence

is      necessary                   for         trial         preparation,                    and            expert                 deposition

testimony.                         Plaintiffs               could         wait          no        longer                 for         necessary


substitution                  of    counsel            documentation                 to be        filed        by the               Defendant,

as    trial        is     less           than     three           months       away.

         5             Plaintiffs                 will        be        severely             prejudiced                    if        expedited

production                    is         not         ordered,                and       will             further                     delay      and

inconvenience.

         WHEREFORE,                  Plaintiffs              moves       this       Court         for Expedited                      Discovery

as    outlined            above.

                                               CER                  TE OF                  SERVIC

            I HEREBY               CERTIFY        that       a true          and     correct            copy        of     the        above     and

foregoing               has        been        furnished           by    U.S.        Mail         to     William               S.     Jonassen,

Esquire,           Post            Office         Box       366,        Indian        Rocks            Beach,            Florida            33785,

and     to        William                H.     Olney,        Esquire,               108     East             Central               Boulevard,

Orlando,           Florida                    32801,        this    Asay               of    March,            2002.



                                                                               iROBE!                     ESQUIRE
                                                                                             1 MERR       ULLES,  TIMM,
                                                                                   FOREN      & GINSBURG,  P.J
                                                                                   Postal         Drawer            4195
                                                                                   Sarasota,  Florida                               34230
                                                                                   (941) 366-8100
                                                                                   Florida             Bar    No.         234230
                                                                                   Attorney             for     Plaintiffs