Free Motion for Extension of Time - District Court of Arizona - Arizona

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DANIEL G. KNAUSS United States Attorney District of Arizona SUZANNE M. CHYNOWETH Assistant U.S. Attorney Arizona Bar Number 6835 40 North Central Avenue, Suite 1200 Phoenix, Arizona 85004 Telephone: (602) 514-7500 Facsimile: (602) 514-7760 email: [email protected]

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA Alexander Jung, Plaintiff, v. John Potter, Postmaster General, U.S. Postal Service Defendant. Defendant hereby requests that the Court extend the deadline for filing the verdict forms CIV-04-0429-PHX-MHM DEFENDANT'S REQUEST TO EXTEND TIME FOR FILING OPPOSITION TO PLAINTIFF'S PROPOSED JURY INSTRUCTIONS AND VERDICT FORMS (Third Request) 1/

15 until after the Court's ruling on the Defendant's motion to continue and other pre-trial issues. 16 Good cause exists for this request because undersigned counsel was unable to communicate 17 substantively with Plaintiff's counsel about the jury instructions until mid-afternoon today. At 18 that time, it was decided that the parties would file their jury instructions independently, and 19 undersigned counsel would file the stipulated joint jury instructions. Due to continuing staffing 20 shortages at the U.S. Attorneys Office, the complexity of this case, and remaining uncertainty 21 about evidentiary and pre-trial issues, it is requested that undersigned counsel be permitted to file 22 verdict and special verdict forms after the Court's rulings on motions in limine and other matters 23 connected with the parties' proposed pre-trial order. Undersigned counsel further requests that 24 the Court waive any requirement that plaintiff's counsel be contacted about his position prior to 25 filing this request for two reasons: Plaintiff's counsel is on his way to Colorado and the Court 26 has a scheduled hearing on June 12, 2007 at 4:00 pm during which time plaintiff can advise 27 further of his position. 28 The parties have previously requested brief extensions due to work load issues (Doc. # 109), and to attend a settlement conference (Doc. # 110).
Case 2:04-cv-00429-MHM Document 132 Filed 06/08/2007 Page 1 of 2
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1 It is therefore requested that the Court extend the time for filing verdict forms until after the 2 Court's ruling on the parties' motion to continue, the pre-trial order, and motions in limine. 3 I, Suzanne M. Chynoweth, by signing below, certify pursuant to Paragraph II(C)(3),

4 District of Arizona ECF Administrative Policies and Procedures Manual (April 3, 2006) that the 5 content of this Stipulation is acceptable to Plaintiffs' counsel. 6 7 8 9 10 11 12 CERTIFICATE OF SERVICE 13 I hereby certify that on June 8, 2007, I electronically transmitted the attached document 14 to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic 15 Filing to the following CM/ECF registrants: 16 Rosval A. Patterson 17 777 E. Thomas Rd. Phoenix, AZ 85014 18 S/ LaRee Zickefoose 19 Office of the U.S. Attorney 20 21 22 23 24 25 26 27 28 2
Case 2:04-cv-00429-MHM Document 132 Filed 06/08/2007 Page 2 of 2

Respectfully submitted this 8th day of June, 2007. DANIEL G. KNAUSS United States Attorney District of Arizona s/Suzanne M. Chynoweth SUZANNE M. CHYNOWETH Assistant U.S. Attorney