Free Motion for Extension of Time - District Court of Arizona - Arizona

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Law Office of James Burr Shields 382 East Palm Lane Phoenix, Arizona 85004-1531 (602) 307-0780 (Office) (602) 307-0784 (Facsimile)
James Burr Shields II, State Bar #011711 John A. Conley, State Bar #016429 Blake Simms, State Bar #021595 Attorneys for Plaintiff

IN THE UNITED STATES DISTRICT COURT IN AND FOR THE STATE OF ARIZONA

) ) ) ) ) Plaintiffs, ) ) vs. ) ) 5. Home Mortgage, Inc., an ) Arizona corporation conducting ) business in Arizona, ) 6. Carl Brown; ) 7. Molly Brown; ) 8. Greg Brown; ) 9. Jane Doe Brown; ) 10. Does 1-10; ) 11. XYZ Corporations; ) 12. Black Partnerships; ) ) Defendants. ) _________________________________)

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Cathleen Channel, Theresa Wharry, Stacie Hanson, Monique Nichols,

Case No. CIV 2003-0100 PHX ROS JOINT MOTION TO EXTEND DISCOVERY AND DISPOSITIVE MOTIONS DEADLINE AND REQUEST FOR EXPEDITED RULING

Plaintiffs, Cathleen Channel, Theresa Wharry, Stacie Hanson, and Monique Nichols, and Defendants, Carl Brown and Molly Brown, by and through counsel undersigned, hereby file their Joint Motion to Extend Discovery and Dispositive Motions Deadline and Request for Expedited Ruling. Pursuant to the Court's March 16, 2006, Rule 16 Scheduling Order, the parties' current discovery deadline is September 1, 2006. The parties are in the process of attempting to work through various discovery issues. The existence of these discovery issues, in addition to Defendants' counsel's need to prepare for and attend two trials during
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Case 2:03-cv-00100-ROS-MEA

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the month of August, have made it impractical for Plaintiffs to depose Defendant Carl Brown before the current discovery deadline. The parties wish to make every effort to resolve their discovery issues without Court intervention, and they believe a one-month extension of the discovery deadline may allow for such a resolution. The parties would like to extend to October 6, 2006, the discovery deadline. Such an extension would also force an extension of the dispositive motions deadline, which is currently October 6, 2006. The parties would like to extend to November 10, 2006, the dispositive motions deadline. As the current discovery deadline is rapidly approaching, the parties also request an expedited ruling hereon. RESPECTFULLY SUBMITTED this 31st day of July, 2006. LAW OFFICE OF JAMES BURR SHIELDS

_s/ W. Blake Simms___________________ James Burr Shields W. Blake Simms Attorneys for Plaintiffs

___s/ W. Blake Simms, with permission, for_ John E. Karow Attorney for Defendants Carl & Molly Brown

CERTIFICATE OF SERVICE I hereby certify that on the 31st day of July, 2006, I electronically submitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants:
John E. Karow, Esq. 11350 North 104th Place Scottsdale, Arizona 85259 Attorney for Defendants Carl and Molly Brown

____s/ Gail Ivey___________________

Case 2:03-cv-00100-ROS-MEA

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