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Re: None

Saturday, 06/19/2021 7:43:19 AM

Saturday, June 19, 2021 7:43:19 AM

Post# of 3281
Reason highlights for Ex Parte to continue the trial.



"PLEASE TAKE NOTICE that Defendants Jeff Bearden, Acembly, Inc.,
Synrgy Corp. and B&D Consulting (collectively, the “Defendants”), hereby apply to this Court, ex parte, pursuant to Local Rule 40-1, for an order continuing the trial in this matter, currently set for August 3, 2021 by at least three months because counsel for Defendants recently learned that he must undergo a medical procedure on his eyes. Defendants brings this ex parte application on the grounds of medical necessity."

"Defendants make this request because, as set forth more fully below, good cause exists for a short continuance given the necessary medical procedure and because Plaintiffs’ counsel has indicated that Plaintiffs do not oppose granting a continuance. Denial of the requested continuance will result in prejudice to Defendants as Defendant’s counsel is currently experiencing severe vision problems and is therefore limited in his ability to operate."

"Beginning mid-May 2021, Defense Counsel Michael B. Wilson (“Mr. Wilson”) began experiencing severe eye problems including objects in his field of vision and severely blurred vision. (Declaration of Michael B. Wilson, filed concurrently herewith (“Wilson Decl.”)"