Free Request - District Court of Arizona - Arizona

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

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 modify the deadlines in its September 22, 2004 and August 25, 2005, orders for filing dispositive motion and for conducting discovery. The parties have been attempting to conduct a settlement conference and exchange necessary information for that process. However, the settlement conference was recently rescheduled to December 14, 2005 to allow the parties to obtain information that would be crucial to a possible settlement Magistrate Aspey's November 21, 2005 Order.] The parties have been attempting to limit discovery to issues associated with settlement efforts. However, if the settlement conference is not successful, additional discovery will be necessary to prepare this case for the filing of dispositive motions and/or trial. Based upon the foregoing and in the interest of judicial economy, it is therefore requested that the Court enter an order extending the discovery deadline until February 21, 2006, and the deadline for filing dispositive motions until March 30, 2006. STIPULATED REQUEST TO EXTEND DISCOVERY AND DISPOSITIVE MOTION DEADLINES (Third Request)

Case 2:04-cv-00429-MHM

Document 33

Filed 11/28/2005

Page 1 of 2

1 2 3 4

Respectfully submitted this 28th day of November 2005. PAUL K. CHARLTON United States Attorney District of Arizona s/Suzanne M. Chynoweth

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 s/Rosval A. Patterson Rosval A. Patterson Patterson & Associates, P.L.L.C. Attorney for Plaintiff Suzanne M. Chynoweth Assistant U.S. Attorney

Case 2:04-cv-00429-MHM

Document 33

Filed 11/28/2005

Page 2 of 2