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

1 TERRY GODDARD ATTORNEY GENERAL 2 ANNE STRATMAN (022301) 3 Assistant Attorney General 177 North Church Avenue, Suite 1105 4 Tucson, Arizona 85701-1114 (520) 628-6044 · Fax (520) 628-6050 5 [email protected] 6 Attorneys for Defendants 7 8 9 10 11 12 13 14 15 16 Defendants, by and through counsel undersigned, hereby request an extension of v. QUIRINO VALERAS, et al., Defendants. IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA PAUL EUGENE RHODES, Plaintiff, No. CV04-0644 PHX-JAT (MS) MOTION FOR EXTENSION OF TIME TO FILE A DISPOSITIVE MOTION

17 time to file a dispositive motion. The deadline to file a dispositive motion is currently set 18 for January 3, 2006 (Dkt. 29). This case involves relatively complex issues regarding the 19 medical care that Plaintiff Rhodes received while he was in prison. Undersigned counsel 20 has recently taken over handling this case and several other cases from another Assistant 21 Attorney General and has been making her best efforts to manage these new cases as 22 efficiently and judiciously as possible. However, undersigned counsel believes a brief 23 extension of time to file a dispositive motion is reasonable, especially given the upcoming 24 holiday season. Therefore, Defendants respectfully request a 30-day extension of time to 25 file a dispositive motion in this matter. 26

Case 2:04-cv-00644-JAT-LOA

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RESPECTFULLY SUBMITTED this

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day of December, 2005.

TERRY GODDARD ATTORNEY GENERAL

s/Anne Stratman ANNE STRATMAN Assistant Attorney General Attorneys for Defendants

9 COPY of the foregoing mailed day of December, 2005 to: this 14 10 Paul Eugene Rhodes, #163870 11 ASPC-Florence-Central Post Office Box 8200 12 Florence AZ 85232 13 14 15 16 17 18 19 20 21 22 23 24 25 26 2 s/CBailey Secretary, Attorney General's Office

IDS05-0164/938704

Case 2:04-cv-00644-JAT-LOA

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