Free Request - District Court of Arizona - Arizona

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PAUL K. CHARLTON United States Attorney District of Arizona SUZANNE M. CHYNOWETH Assistant U.S. Attorney Arizona State Bar No. 6835 Two Renaissance Square 40 North Central Avenue, Suite 1200 Phoenix, Arizona 85004-4408 Telephone: (602) 514-7500 Facsimile: (602) 514-7760 E-Mail: [email protected]

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA Alexander Jung, CIV-04-0429-PHX-MHM Plaintiff, v. John Potter, Postmaster General, U.S. Postal Service, Defendant. The parties hereby request that the Court allow a brief period to complete discovery after the Court's ruling on dispositive motions, which are due by March 30, 2006. While the parties have completed the majority of discovery, there are several depositions that will need to be taken should this matter go to trial. Most of these depositions involve travel and/or a fee that will be required for deposing a treating physician. Furthermore, there may be additional discovery needed due to the clarification of issues from the ruling on the dispositive motions. Consequently the parties request that the Court permit those depositions and any remaining discovery be taken during a sixty (60) day period after the Court's ruling on dispositive motions. The parties have made every effort to minimize costs in this case to increase the chances that this case will settle and in consideration of the parties' respective budgetary restrictions. Although settlement negotiations have not yet been successful, the case may still settle after the Court's ruling on dispositive motions. Based upon the foregoing, it is STIPULATED REQUEST TO EXTEND DISCOVERY DEADLINES

Case 2:04-cv-00429-MHM

Document 48

Filed 02/22/2006

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1 therefore requested that the Court permit a brief period of discovery after its ruling on dispositive 2 motions. 3 4 5 6 7 s/Suzanne M. Chynoweth 8 9 10 s/Rosval A. Patterson 11 Rosval A. Patterson 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2
Patterson & Associates PC

Respectfully submitted this 22nd day of January 2006.

PAUL K. CHARLTON United States Attorney District of Arizona

Suzanne M. Chynoweth Assistant U.S. Attorney

Attorney for Plaintiff

Case 2:04-cv-00429-MHM

Document 48

Filed 02/22/2006

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CERTIFICATE OF SERVICE

I hereby certify that on February 22, 2006 I electronically transmitted the attached

4 document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice 5 of Electronic Filing to the following CM/ECF registrants: 6 7 Rosval A. Patterson 777 E. Thomas Rd. 8 Phoenix, AZ 85014 9 10 s/Jennifer Maughan ________________________________ 11 Office of the U.S. Attorney 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3

Case 2:04-cv-00429-MHM

Document 48

Filed 02/22/2006

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