The scheduling issues in this case clearly are the result of (Kelly’s) lack of familiarity with the mechanics of the new scheduling rules and the virtual gutting of Rule 38.1, Ariz. R. Civ. P.

For example, had Plaintiff timely propounded discovery on May 29, 2015, as permitted by the scheduling order, the responses would not have even been due until July 13, 2015, leaving a little more than two weeks to satisfy Rules 26(g) and 37(a)(2)(C), Ariz. R. Civ. P., then file a motion to compel if efforts to obtain the discovery were unsuccessful, in order to meet the discovery cutoff date. The scheduling issues in this case clearly are the result of lack of familiarity with the mechanics of the new scheduling rules and the virtual gutting of Rule 38.1, Ariz. R. Civ. P.

Matthew Kelly of Kelly McCoy PLC unfamiliar with Arizona Rules of Civil Procedure
Matthew Kelly of Kelly McCoy PLC unfamiliar with Arizona Rules of Civil Procedure

Todd and Robyn Burke Arizona Federal Bankruptcy

Todd and Robyn Burke
3275 E. Cardinal Court
Chandler, AZ 85286

CorVent Medical
4837 Amber Valley Pkwy S,
Fargo, ND 58104
(917) 494-9184
CorVentMedical.com

Jim Jake
Global Vice President

Patsy Polatcheck
Director of Customer Service
__________________________________
Area Sales Manager
The Morel Company
300 Winding Way
Batesville, IN 47006

Hercules Patient Repositioner
morelcompany.com

Bill Hillenbrand
President and Chief Executive Officer (CEO)

Tim Savage
Vice President

Joe Kummer
Vice President – Operations and Product Development

Doug Kunkel
Chief Financial Officer (CFO)

Kevin McCoy
Matthew Kelly
Kelly-McCoy PLC

todd_robyn_burke_morel_company

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