United States District Court
Middle District of Florida
Fort Myers Division 


_______________________ 
Sheri Patriot,              : 
Petitioner, pro se,         :   Case No. 2:07-cv-372-FtM-34DNF 
                            :
    vs.                     :
                            :   Motion for Extension of Discovery
AmSouth Bank and            :
United States of America,   :
Respondents                 :
 _________________________

  COMES NOW, Petitioner, pro se, Sheri Patriot, and for her motion to extend Discovery to allow Respondents sufficient time to respond to Requests for Documents and Interrogatories, states and alleges as follows:

  1. Originally, Petitioner had requested only one month for Discovery.  Unlike the inexperienced Petitioner, the Court understood one month was not enough time and wisely allowed four months on July 17, 2007.
  2. Unbeknownst to Petitioner, she did not realize she would be loosing more than two months  preparing several Court documents, such as the following:

    3. a) Aug. 6, 2007, Petitioner's compliance to July 17, 2007 Court Order

    b) Aug. 6, 2007, Petitioner's Motion for Default Judgment re AmSouth

    c) Aug. 27, 2007, Petitioner's Motion for Extension to ‘Re-Serve'AmSouth

    d) Oct. 18, 2007, Petitioner's Opposition to Motion to Dismiss AmSouth

    e) Oct. 22, 2007 Petitioner filed and mailed Requests for Documents and Interrogatories to both Respondents.

  3. With the exception of the recent extension needed to “RE-Serve” AmSouth Bank, Petitioner has never asked this Court for an extension over the past three years during the course of three separate cases.  She has always been able to timely file her papers.
  4. As noted above in #2 (e), Petitioner has filed and mailed her Requests and her Interrogatories today. However, to be fair to all Parties, Petitioner is        requesting one more month of Discovery which would make Discovery a total of five months.

Conclusion WHEREFORE, PREMISES CONSIDERED, Petitioner prays this Court will be lenient with this pro se Petitioner, and moves this Court to grant this extension, and adjust the hearing date, so the Respondents will have more than enough time to complete Discovery. 

By:__________________________________
   Sheri Patriot, Petitioner, pro se

Certificate of Service:   I do hereby certify that on this date I have properly mailed copies of the foregoing document, postage prepaid and properly addressed to the opposing parties. 

Philip Doyle, Trial Attorney                        Luis E. Rivera, II & John A. Noland 
U.S. Department of Justice Date                     Henderson, Franklin, Starnes & Holt      
P.O. Box 14198                                      P.O. Box 280
Ben Franklin Station                                Fort Myers, FL  33902-0280
Washington, D.C. 20044 

_________________________________                 ________________________
Sheri Patriot, Petitioner, pro se                 Date