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IN THE CIRCUIT COURT OF TENNESSEE FOR THE
THIRTIETH JUDICIAL DISTRICT AT MEMPHIS
GEORGE L. GREER,
Plaintiff,
vs.
No. 57257-7 T.D.
EVELYN THOMAS,
Defendant.
MOTION FOR EXPEDITED DISCOVERY
TO THE HONORABLE ROBERT A. LANIER, JUDGE OF DIVISION VII OF
THE CIRCUIT COURT OF TENNESSEE FOR THE THIRTIETH JUDICIAL
DISTRICT AT MEMPHIS:
COMES NOW your plaintiff, George L. Greer, through his
undersigned counsel of record, pursuant to Rule 30.01 of
the Tennessee Rules of Civil Procedure and moves for leave
of Court to take depositions prior to the expiration of 30
days after service of the Summons and Complaint upon the
defendant. In support of his motion, your plaintiff would
show unto the Court as follows:
.
Plaintiff filed this complaint on October 20,
1993, after it had become apparent that defendant removed
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all plaintiff's property from plaintiff's residence at 1497
Fields Road without plaintiff's consent.
.
Plaintiff fears that defendant is hiding and
disposing of all of plaintiff's property.
.
To have any hope of regaining any of plaintiff's
property, it is necessary to quickly discover where
plaintiff's property has been concealed.
WHEREFORE, PREMISES CONSIDERED, YOUR PLAINTIFF PRAYS
that this Court grant leave for plaintiff to take expedited
discovery in this cause.
Respectfully submitted,
GLANKLER BROWN
1700 One Commerce Square
Memphis, Tennessee 38103
901/525-1322
By:
Robert L. Hutton (#15496)
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