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 modify the deadlines in its September 22, 2004 and

STIPULATED REQUEST TO EXTEND DISCOVERY AND DISPOSITIVE MOTION DEADLINES (SECOND REQUEST)

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April 26, 2005 orders for filing dispositive motion and for conducting discovery. Based upon

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unforeseen information that evolved from depositions that were taken last month, the parties have

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identified areas in which additional discovery is needed that would impact their ability to file successful

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dispositive motions and/or resolve this case without further litigation. For example, agency counsel for

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the United States Postal Service will be assisting in document review in September to help resolve these

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issues. Further, the parties are in the process of scheduling a settlement conference that would take

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place in October, after the aforementioned discovery issues have been resolved. This extension request

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would ideally, and potentially result in a resolution of the case, which would save the parties and the

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Court time and money.

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Based upon the foregoing and in the interest of judicial economy, it is therefore requested that

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the Court enter an order extending the discovery deadline until November 30, 2005, and the deadline

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for filing dispositive motions until December 30, 2005.

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Case 2:04-cv-00429-MHM

Document 25

Filed 08/18/2005

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1 2 3 4 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 Suzanne M. Chynoweth Assistant U.S. Attorney PAUL K. CHARLTON United States Attorney District of Arizona

Case 2:04-cv-00429-MHM

Document 25

Filed 08/18/2005

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CERTIFICATE OF SERVICE

I hereby certify that on August 18, 2005, 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 25

Filed 08/18/2005

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