Free Motion for Leave to File - District Court of Arizona - Arizona

R ANDOLPH G . B ACHRACH
ATTORNEY AT LAW

5103 E. THOMAS ROAD PHOENIX, ARIZONA 85018 Tel: (602) 852-9540 Fax: (602) 840-0318 (AZ #12621 - CA #93278)

Attorneys for Plaintiff

United States District Court
FOR THE DISTRICT OF ARIZONA

DAVID L. MAZET, Plaintiff, vs. HALLIBURTON COMPANY LONGTERM DISABILITY PLAN; and, HARTFORD LIFE & ACCIDENT INSURANCE COMPANY, Defendants.

No.: CV 04 0493 PHX FJM PLAINTIFF'S OPPOSITION TO DEFENDANTS' REQUEST FOR LEAVE TO FILE SUPPLEMENTAL BRIEF IN OPPOSITION OF PLAINTIFF'S SUR-RESPONSE; REQUEST FOR LEAVE TO FILE SUPPLEMENTAL REPLY IN SUPPORT OF PLAINTIFF'S SUR-RESPONSE

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Plaintiff objects to Defendants' Request for Leave to file yet another brief related to Plaintiff's pending Motion for Remand, etc. Plaintiff did not raise "two new issues" in his Sur-response, as Defendants claim in their Request for Leave. (Docket # 92, pg. 1.) These issues (the CPI-W and estimated median wages) have been extensively briefed by all the parties. Furthermore, Defendants have once again egregiously misstated the record in this case, on these issues. Therefore, should the Court grant Defendants' requested leave, Plaintiff (the moving party) requests leave to file a brief supplemental reply to address the issues raised by Defendants in their supplemental response. DATED: August 18, 2008 RANDOLPH G. BACHRACH Attorney at Law By s/Randolph G. Bachrach Randolph G. Bachrach, Esq. 5103 E. Thomas Road Phoenix, Arizona 85018 Attorney for Plaintiff
Case 2:04-cv-00493-FJM Document 94 Filed 08/18/2008 Page 1 of 2

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I hereby certify that on August 18, 2008 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:
Steve Bressler Ricki L. Cohen LEWIS & ROCA, LLP 40 N. Central Ave. Phoenix, Arizona 85004-3329 Attorneys for Defendants s/Randolph G. Bachrach

ATTORNEY AT LAW 5103 E. THOMAS ROAD PHOENIX, AZ 85018 S (602) 852-9540

RANDOLPH G. BACHRACH

0308

Case 2:04-cv-00493-FJM

Document 94 2 Filed 08/18/2008

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