IN THE 19TH JUDICIAL CIRCUIT FOR THE STATE OF MISSOURI
Lee Allen Martin pro se Attorney VS. Director of Revnue, et al Keith D. Halcomb Attorney
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CASE #01CV324209
RULE 65 MOTION FOR CONTINUANCE
Comes now the plaintiff,
Lee Allen Martin, and must request a continuance pursuant to Missouri Supreme
Court Rule 65, 65.01, and 65.03. The plaintiff does state that the court has not ruled upon Discovery Motions.
1) The Motion before the court to reconsider Courts ruling concerning Production of Documents that was heard on the 7th day of January 2002 has not been ruled upon as of this date, 24 January 2002.
2) Motion to Compel Answer to Interrogatories have not been ruled upon filed the 7th day of January 2002.
3) Plaintiff did announce to the Court on the 28th day of November 2001 of Plaintiff's intention to submit Admissions to the defendant upon cmpleting the Interrogatories and Production of Documents. Pursuant to the Misssouri Supreme Court Rule 59.01 upon submission of the Admissions the responding party has within 30 days to respond. Therefore, the plaintiff must request of this honorable court that the case at hand be continued to the earliest trial date available after May 1st 2002, or 30 days after all finishing the discovery process in this action.
Respectfully Submitted
Lee Allen Martin 7050 County Road 2810 West Plains Missouri, 65775
CERTIFICATE OF SERVICE
I hereby certify this pleading was served upon all attorneys of record for each of the parties to this action and All parties not represented by counsel in the following manner: [ ] By delivering a copy to them. [ ] By leaving a copy at their office with the clerk. [ ] By leaving a copy at them office with an attorney associated with them. [ ]By mailing a copy to them as prescribed by law [ ] By faxing a copy to them. 24th day of January, 2002
So certified: _____________________________ Lee Allen Martin
NOTICE OF HEARING
The foregoing pleading will be called for hearing before the court onFebruary 4, 2002at 1 pm or as soon thereafter as petitioner may be heard. So noticed: