Free Motion to Continue - District Court of Arizona - Arizona

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19

Eric G. Slepian Bar # 017495 SLEPIAN LAW OFFICE 3737 N. 7th Street, Ste. 106 Phoenix, Arizona 85014 Telephone (602) 266-3111 Attorney for Plaintiff UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Angela Jolicoeur, Plaintiff, vs. Midland Credit Management Long Term Disability Plan; UnumProvident a/k/a UNUM Life Insurance Company of America, Defendants. NO. CIV-04-0499-PHX-SRB PLAINTIFF'S MOTION TO CONTINUE THE SCHEDULING CONFERENCE

(Assigned to the Honorable Susan R. Bolton)

A Scheduling Conference is currently set for Monday April 2, 2007 at 4:00 p.m. Plaintiff's counsel is not available at this time secondary to the Jewish Holiday. Therefore, the parties agree to reschedule the hearing. Pursuant to the Court's instructions, the parties are attempting to provide the

20 21 22 23 24 25

Court with reasonable alternative dates for the conference. So far, it has been ascertained that the parties are not available to reschedule the Scheduling Conference until June, 2007. Plaintiff does not believe that this date is reasonable and, accordingly, it is believed that counsel will need to readjust their schedules so the conference can be held within the next 45 days. The parties need more time to select an appropriate

26 27 28

Monday for the Scheduling Conference. Accordingly, it is requested that the conference

-1-

Case 2:04-cv-00499-SRB

Document 46

Filed 03/30/2007

Page 1 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

be cancelled with instructions for counsel to choose an alternative date that is reasonable. DATED this 30th day of March, 2007. THE SLEPIAN LAW OFFICE

By __s/Eric G. Slepian____________ Eric G. Slepian, Esq. Attorney for Plaintiff

CERTIFICATE OF SERVICE I hereby certify that on March 30, 2007, I electronically transmitted 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: Ann-Martha Andrews, Esq. Lewis & Roca, LLP 40 North Central Avenue Phoenix, AZ 85004-4429 Attorney for Defendant UNUM Life Insurance Co. R. Shawn Oller, Esq. Littler Mendelson 2425 E. Camelback Road, Ste. 900 Phoenix, AZ 85016 Attorney for Defendant Midland Credit Management s/ Genesia Conover SLEPIAN LAW OFFICE

-2-

Case 2:04-cv-00499-SRB

Document 46

Filed 03/30/2007

Page 2 of 2