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

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TERRY GODDARD ATTORNEY GENERAL ANNE STRATMAN (022301) Assistant Attorney General 177 North Church Avenue, Suite 1105 Tucson, Arizona 85701-1114 (520) 628-6044 · Fax (520) 628-6050 [email protected] Attorneys for Defendant IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

Paul Eugene Rhodes, Plaintiff, v. Quirino Valeros, et al., Defendants.

No: CV04-0644-PHX-JAT (MS) MOTION FOR ENLARGEMENT OF TIME TO DEPOSE PLAINTIFF AND TO WITHDRAW NOTICE OF DEPOSITION

Defendants Allred, Pinkstaff, Pratt, Shiflett, Rivas, Buffington, Kumar, Strubeck, Lesac and Greeley,1 by and through counsel undersigned, hereby request an enlargement of time to depose Plaintiff, and to withdraw its Notice of Deposition. According to this Court's Scheduling Order (Dkt. 29), the deadline for taking Plaintiff's deposition is November 3, 2005, and the deposition has been noticed for November 1, 2005 (Dkt. 39). Defendants respectfully request an enlargement of time because the Assistant Attorneys General representing Defendants have recently changed hands. The Assistant Attorney General now handling this matter has taken on much of the previous Assistant Attorney

Dennis Chenail was dismissed from the action in the Court's June 14, 2005 Screening Order.
Case 2:04-cv-00644-JAT-LOA Document 42 Filed 10/14/2005 Page 1 of 2

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General's caseload, and has not yet had sufficient time to review the voluminous legal file in this case or adequately prepare for Plaintiff's deposition. Defendants believe that this request is reasonable under the circumstances. They request that the Court extend the deadline for taking Plaintiff's deposition for three weeks, or until November 23, 2005.

RESPECTFULLY SUBMITTED this

day of October, 2005. Terry Goddard Attorney General

Anne V. Stratman Assistant Attorney General Attorneys for Defendants

Copy mailed the same date to: Paul Eugene Rhodes, #163870 ASPC-Florence-Central Post Office Box 8200 Florence AZ 85232

Secretary, Attorney General's Office
IDS05-0164 / 929217

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

Document 42

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Filed 10/14/2005

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