COMES NOW, Plaintiff, Marquitta L. Portman, in the above styled action and moves this Court to extend the time within which plaintiff may engage in discovery.

Plaintiff shows the appropriate Court that the deadline to engage in discovery is March 7, 2000; that defendant parties have filed Motions for Protective Orders,--------- Objections, and Motions to Dismiss, seeking to limit and/or prohibit discovery in this instant case; that in order to afford the appropriate Court time within which to rule on these discovery motions thereby defining for the parties the scope of discovery; plaintiff needs additional time beyond the March 7, 2000 discovery deadline in which to complete intended discovery.

Plaintiff also shows the appropriate Court that defendant parties have failed to initiate any kind of meaningful discovery during the period of October 7, 1999 until March 6, 2000. Plaintiff respectfully requests that defendants' have, therefore, yielded their right to any extension of meaningful discovery.

Further, the Honorable Kenneth O. Nix has failed to adhere to Superior Court Rule 25.3 and has failed to "immediately determine the timeliness of the motion and the legal sufficiency of the affidavit" in the matter of Plaintiff's Motion to Disqualify the Honorable Kenneth Nix.

Plaintiff requests permission to Amend her Motion to Disqualify the Honorable Kenneth Nix to include as an additional reason for Judge Nix's disqualification, Opinion 220 of the Judicial Qualifications Commission, Docket No. 97-78, issued the 25th of April, 1997 and quoted herein:

"Simply stated, the public must believe in the absolute integrity and impartiality of its judges, and it is the obligation of this Commission to support and encourage such belief. Consequently, even without a showing of actual bias, prejudice or unfairness, and regardless of the merits or timeliness of a Motion to Recuse, this Commission concludes that it is inappropriate for any trial court judge to preside in any action wherein one of the parties holds a judicial office on the same or any other court which sits in the same circuit. Accordingly, the question posed is answered in the negative."

Pursuant to Opinion 220 of the Judicial Qualifications Commission, it is solely the responsibility of this Court to voluntarily, and timely, recuse from presiding in the instant case for the reason that, "one of the parties holds a judicial office on the same [or any other] court which sits in the same circuit."

Because it is the DUTY of the Court to voluntarily and timely recuse, Plaintiff's Motion to Disqualify ANY TRIER OF THE SAME CIRCUIT, is actually beyond the scope of any citizen's responsibilities.

Plaintiff shows the appropriate Court that the six month delay, which is the direct result of the failure of this Court to adhere to Georgia Law, has further violated Plaintiff's right to due process under the U.S. Constitution.

WHEREFORE, Plaintiff prays that:

• this Court immediately recuse all judicial officers of the Cobb Circuit,
  
  
• that this Court immediately direct this instant case to the appropriate judicial body for assignment of a fair and impartial adjudicator,
  
  
• that the assigned appropriate Court grant Plaintiff an extension of 90 days in which to engage in meaningful discovery,
  
  
• that the assigned appropriate Court deny all Defendants' Motions for Protective Order, Motions to Quash, and Motions to Dismiss.
  
  
• that Plaintiff be granted any further relief as determined by the appropriate Court.