Free Motion to Continue - District Court of Arizona - Arizona

1 2 3 4 5 6 7 8 9

Bruce Friedman (pro hac vice admission) Mark S. Fragner (pro hac vice admission) RUBIN, FIORELLA & FRIEDMAN LLP 292 Madison Avenue New York, NY 10017 Telephone: (212) 953-2381 Facsimile: (212) 953-2462 Gerald Gaffaney, No. 003789 David J. Ouimette, No. 006423 MARISCAL, WEEKS, McINTYRE & FRIEDLANDER, P.A. 2901 North Central, Ste. 200 Phoenix, AZ 85012 Telephone: (602) 285-5000 Facsimile: (602) 285-5100 Attorneys for Plaintiffs

10 11 12 13 14 15 16 17 18 19 20 21

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA U-HAUL INTERNATIONAL, INC.; U-HAUL COMPANY OF PENNSYLVANIA; U-HAUL COMPANY OF FLORIDA; and REPUBLIC WESTERN INSURANCE COMPANY, Plaintiffs, vs. LUMBERMENS MUTUAL CASUALTY COMPANY, Defendant. Each of the parties, through their respective undersigned counsel, and pursuant to CASE NO. CIV-04-0662-PHX-DGC (Maricopa County Superior Court Case No. CV 2004-002438) JOINT STIPULATED MOTION FOR CONTINUANCE OF FINAL PRETRIAL CONFERENCE AND EXTENSION OF DEADLINES FOR FILING OF PROPOSED FINAL PRETRIAL ORDER (Second Request)

22

L.R. Civ. 7.3, hereby jointly submit this stipulated motion to continue the scheduled date of
23 24 25 26

the Final Pretrial Conference and to extend the deadlines set forth in this Court's recent Order Continuing Final Pretrial Conference and Continuing Associated Deadlines, dated November 14, 2006. In support thereof, the parties state as follows:

Case 2:04-cv-00662-DGC

-1Document 142

Filed 12/22/2006

Page 1 of 3

1 2 3 4 5

1.

This is the second request for an extension of the dates originally set forth in

the Court's October 13, 2006 Order. 2. The client representatives to whom counsel for Plaintiffs and for Defendant

report and who are necessary for the preparation of the Joint Pretrial Order and all associated filings are unavailable and will be out of the office until January 2, 2007.

6 7 8 9 10 11 12 13 14

3.

For this reason, and due to the intervening holidays, the parties therefore will

need additional time to prepare the Proposed Joint Final Pretrial Order, and agree that neither would be prejudiced by the requested continuance. For the foregoing reasons, the parties respectfully request entry of an Order continuing the Final Pretrial Conference until a date on or after February 28, 2007, and extending the deadlines for exchanging drafts of the Proposed Final Pretrial Order, for exchanging copies of exhibits, and for filing a Proposed Final Pretrial Order until appropriate dates determined by reference to the date to be established for the Final

15

Pretrial Conference, in substantially the form of proposed Order submitted herewith.
16 17 18 19 20 21 22 23 24 25 26

Case 2:04-cv-00662-DGC

-2Document 142

Filed 12/22/2006

Page 2 of 3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15

RESPECTFULLY SUBMITTED this _____ day of December, 2006. RUBIN, FIORELLA & FRIEDMAN LLP and MARISCAL, WEEKS, MCINTYRE & FRIEDLANDER, P.A.

By:

/s/ Gerald Gaffaney - with permission Gerald Gaffaney David J. Ouimette

Attorneys for Plaintiffs/Counterclaim Defendants

BESS KUNZ, A Professional Corporation and WALTON LANTAFF SCHROEDER & CARSON LLP

By
16 17 18 19 20 21 22 23 24 25 26

/s/ Daniel Maldonado Steven Plitt Daniel Maldonado Attorneys for Defendant/CounterPlaintiff

Case 2:04-cv-00662-DGC

-3Document 142

Filed 12/22/2006

Page 3 of 3