Free Stipulation - District Court of Arizona - Arizona

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40 North Central Avenue Phoenix, Arizona 85004-4429 Facsimile (602) 262-5747 Telephone (602) 262-5311 Stephen M. Bressler (09032) Scott Bennett (022350) Attorneys for Plaintiff United of Omaha Life Insurance Company

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

10 United of Omaha Life Insurance Company, a ) ) 11 Nebraska corporation, ) 12 Plaintiff, ) ) 13 vs. ) ) 14 Tanya Edmondson, Debrah Keys, Catholic ) 15 Cemeteries of The Diocese of Phoenix, and ) ) 16 Falconer Funeral Home, ) 17 Defendants. ) ) 18 19

No. CV 04-0461 PHX-JAT STIPULATION TO EXTEND UNITED OF OMAHA'S TIME TO FILE A REPLY IN SUPPORT OF ITS MOTION FOR ATTORNEYS' FEES

Plaintiff United of Omaha and defendant Debrah Keys stipulate that United may

20 have a two-week extension of time to file a reply in support of its motion for attorneys' 21 fees and non-taxable expenses. (Keys is the only defendant with an interest in this issue 22 because the fees and expenses will be deducted from the life-insurance benefit that this 23 Court awarded her.) The reply is currently due Monday, September 26, 2005. The two24 week extension would extend that deadline to October 10, 2005. 25 United requests this extension because its counsel has been and still is in trial,

26 Leavey v. Provident Life, No. CIV-02-2281-PHX-SMM. The trial is presently expected 27 to the jury on Friday, September 30, 2005. A two-week extension will give United's 28 counsel one week after the Leavey case goes to the jury to prepare the reply in this case.
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Counsel for Debrah Keys has given counsel for United permission to sign on her

A proposed order is attached. RESPECTFULLY SUBMITTED this 23rd day of September, 2005. LEWIS AND ROCA LLP LAW OFFICES OF BARBARA H. KATSOS, P.C. s/Barbara H. Katsos Barbara H. Katsos Attorneys for Defendant Debrah Keys By

s/Stephen M. Bressler Stephen M. Bressler Scott Bennett Attorneys for Plaintiff United of Omaha Life Insurance Company

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I hereby certify that on September 23, 2005, 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: John M. McKindles McKindles Law Firm, P.L.L.C. 1108 East Greenway, Suite 1 Mesa, Arizona 85203 Attorney for Defendant Falconer Funeral Home, Inc. Ronald W. Meyer One Columbus Plaza 3636 North Central Avenue, Suite 700 Phoenix, Arizona 85012 Attorney for Defendant Catholic Cemeteries of the Diocese of Phoenix I hereby certify that on September 23, 2005, I served the attached document via U.S. Mail on the following, who are not registered participants of the CM/ECF System: Barbara H. Katsos Law Offices of Barbara H. Katsos, P.C. 777 Third Avenue, Suite 3200 New York, NY 10017 Attorney for Defendant Keys

s/Jody A. Crain

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