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9. A trial court has broad discretion in controlling the time and scope of discovery Rice v. Cannon, 283 Ga App.

438, (1) (641 S.E. 2d 562) (2007); Bicknell v. CBT Factors Corp., 171 Ga. App. 897, 898-899 (321 S.E. 2d 383) (1984). 10. A motion to extend discovery can be filed even after the period of discovery has run. Bullard v. Bouler et al, 272 Ga. App. 397 (2005). 11. Discovery is broad in cases involving custody, and it is common for the discovery period to remain open until the time of trial, given that new developments frequently arise in the midst of litigation. 12. Plaintiff requires this extension of discovery to fairly present his case. Plaintiff would be prejudiced by Former Counsels inaction and it would be manifestly unfair for Plaintiff to proceed to trial without benefit of any discovery having been conducted. 13. Accordingly, Plaintiff seeks an order for this Court reopening the discovery period and extending the discovery deadline through and including November 2, 2013, approximately six months from the time the Court granted the order for Plaintiffs Former Counsel to withdraw. As Defendant has offered little cooperation to the guardian ad litem and even less cooperation with Plaintiff, a need for time to compel Defendants cooperation is anticipated.

CAFN: 12-CV-1077-TB (Paulding County) Plaintiff's Motion to Reopen/Extend Discovery

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