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

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TERRY GODDARD ATTORNEY GENERAL (FIRM STATE BAR NO. 14000) J. D. NIELSEN ASSISTANT ATTORNEY GENERAL CRIMINAL APPEALS SECTION 1275 W. WASHINGTON PHOENIX, ARIZONA 85007B2997 TELEPHONE: (602) 542B4686 [email protected] (STATE BAR NUMBER 007715) ATTORNEYS FOR RESPONDENTS

UNITED STATES DISTRICT COURT
DISTRICT OF ARIZONA
ROBERT ALLEN POYSON,
Petitioner,

CIV 04-0534-PHX-NVW

-vsDORA B. SCHRIRO, et al.,
Respondents.

MOTION FOR EXTENSION OF TIME

For the reasons given in the accompanying Memorandum of Points and Authorities, Respondents respectfully request a 3-week extension, until October 21, 2005, to file their Responses to Petitioner's First Motion to Expand the Record and Petitioner's Motion for Discovery and Evidentiary Hearing. DATED this 29th day of September, 2005.
Respectfully submitted, TERRY GODDARD Attorney General

s/ J. D. NIELSEN Assistant Attorney General Attorneys for Respondents

Case 2:04-cv-00534-NVW

Document 43

Filed 09/29/2005

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MEMORANDUM OF POINTS AND AUTHORITIES Respondents received Petitioner's Motion to Expand the Record and

4 Petitioner's Motion for Discovery and Evidentiary Hearing on September 20, 5 2005. Respondents' attorney has been working diligently since receiving these 6 motions, and has already finished a draft Response to Petitioner's Motion to 7 8 Expand the Record. Because of the complexity and substantive nature of the 9 issues involved, Respondents need more time than the standard 10-day period in 10 order to allow for editing of their draft Response to Petitioner's first motion, and 11 12 the drafting and editing of their Response to Petitioner's second motion. 13 Accordingly, Respondents are requesting a 3-week extension, until October 21, 14 2005, to file their Responses to these motions. Petitioner's attorney, Mr. Burke, 15 16 does not object to the proposed continuance, and Respondents' attorney does not 17 anticipate that any additional extensions will be necessary. 18 DATED this 29th day of September, 2005. 19 20 21 22 23 24 25 26 27 28
Case 2:04-cv-00534-NVW Document 43 2 Filed 09/29/2005 Page 2 of 3

Respectfully submitted, TERRY GODDARD Attorney General

s/ J. D. NIELSEN ASSISTANT ATTORNEY GENERAL ATTORNEYS FOR RESPONDENTS

1 2 I hereby certify that on September 29, 2005, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and 3 transmittal of a Notice of Electronic Filing to the following CM/ECF registrant: 4 JON M. SANDS Federal Public Defender 5 MICHAEL L. BURKE Assistant Federal Public Defender 6 850 West Adams St., Suite 201 Phoenix, Arizona 85007 7 8 Attorney for Petitioner 9 10 s/J. D. Nielsen

11 CRM98-1682 122698 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Case 2:04-cv-00534-NVW Document 43 3 Filed 09/29/2005 Page 3 of 3