Free Request - District Court of Arizona - Arizona

1 ANDREW P. THOMAS
MARICOPA COUNTY ATTORNEY
2
By: JOSEPH I. VIGIL
3 State Bar No. 018677
Deputy County Attorneys
4 MCAO Firm No. 00032000
5 CIVIL DIVISION
Security Center Building
6 222 North Central Avenue, Suite 1100
Phoenix, Arizona 85004-2206
7 Telephone (602) 506-8541
8 Attorneys for Maricopa County
g IN THE UNITED STATES DISTRICT COURT
10 FOR THE DISTRICT OF ARIZONA
11 Connie R. Zakrajsek, NO. CV04-0449 PHX SMM
12 Plaintiff, DEFENDANTS’ JOINT REQUEST
FOR SUMMARY DISPOSITION OF
13 v. ALL PENDING MOTIONS FOR
SUMMARY JUDGMENT
14 Susan Armstrong, an individual; Susan
Armstrong, an employee of the County
15 of Maricopa, Arizona; Richard
Teenstra, an individual; Richard
16 Teenstra, an employee of the County
of Maricopa; County of Maricopa,
17 Arizona, as the employer of Susan
Armstrong and Richard Teenstra; Hon.
18 Colin Campbell, Presiding Judge of
Maricopa County Superior Court,
19 individually and in his capacity as
Presiding Judge; and Does 1-25,
20
Defendants.
21
22
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se 2:O4—cv—OO449—SMM Document 49 Filed O1/O4/2006 Page 1 of 4

1 Defendants, by and through undersigned counsel, hereby submit this
2 Request for the Court to Rule upon the pending Motions for Summary
3 Judgment. Plaintiff has failed to tile any response to either one of the Motions
4 for Summary Judgment and the time has passed for her to submit her
5 responses.
6 On or about August 22, 2005, Defendant Maricopa County tiled its Motion
7 for Summary Judgment and its Separate Statement of Facts. (See docket
8 numbers 22 & 23.) The State Defendants subsequently Hled their Motion for
9 Summary Judgment on September 1, 2005. (See docket numbers 35 & 36.)
10 The Court then set a deadline for Plaintiff to tile her response of October 7,
11 2005. For some reason, Plaintiff could not comply with this deadline and
12 submitted a Motion to Postpone that deadline. The Court granted this request
13 for an extension of time and indicated that Plaintiff was to tile her response to
14 the Motions for Summary Judgment no later than November 15, 2005. (See
15 docket 45.) The Court also indicated that there would be no further extensions
16 of time in this case.
17 It is now January 2006 and Plaintiff has failed to comply with the
18 mandates of this Court. It is clear that Plaintiff must not have confidence in her
19 case as she is willfully ignoring deadlines. Defendant’s respectfully request that
20 the Court rule on the Motions for Summary Judgment and enter a Judgment in
21 favor of Defendants in this matter and dismiss the Plaintiffs case. Defendant’s
22 also request that the Court enter a finding that Plaintiff has not been attempting
· C se 2:O4—cv—O0449—SMM Document 49 2FiIed O1/O4/2006 Page 2 of 4

1 to prosecute her case as the only time she tiles something is when she wants an
2 extension of time. As this Court has pointed out, she gets no more extensions
3 of time and Judgment should be rendered against her and in favor of
4 Defendants.
5 f RESPECTFULLY SUBMITTED this 4th day of January, 2006.
6 ANDREW P. THOMAS
MARICOPA COUNTY ATTORNEY
7
8
BY: s/Joseph I. Vigil
9 JOSEPH l. VIGIL
Deputy County Attorneys
10 Attorneys for Maricopa County
11 ATTORNEY GENERAL’S OFFICE _
12
13 BY: s/Carrie Brennan
CARRIE J. BRENNAN
14 Assistant Attorney General
Attorneys for State Defendants
15
16 ORIGINAL of the foregoing E—FILED
this 4th day of January, 2006:
17
Honorable Stephen M. McNamee
18 United States District Court Judge
Sandra Day O’Connor U.S. Courthouse
19 401 West Washington Street
Phoenix, AZ 85003
20
and copies mailed to:
21
22
3
C se 2:O4—cv—O0449—SMM Document 49 Filed O1/O4/2006 Page 3 of 4

1 Carrie J. Brennan
Assistant Attorney General
2 1275 W. Washington Street .
Phoenix, Arizona 85007
3 Attorneys for State Defendants
4 Connie R. Zakrajsek
P.O. Box 2065
5 Phoenix, Arizona 85001
Plaintiff Pro Se
6
7
s/gill Lafornara
8
ml/no4-ooo
9 S:\COUNSEL\CivlI\Matters\RM\2004\Zakra]sek RM04-060\PLEADlNGS\Request for Summary Disposition.doc
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