Free Stipulation - 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. The parties hereby request that the Court extend the deadline for filing the joint voir dire, jury instructions and verdict forms from one week, from June 1, 2007 until June 8, 2007. [Doc. # 112.] Good cause exists for this request because the parties have been diligently working to complete the exhibit lists and joint pre-trial order by the June 1, 2007 deadline and will meet that deadline. However, due to an extremely heavy work load and resource limitations, Defense counsel was unable to provide Defendant's suggested versions to Plaintiff's counsel prior to June 1, 2007. Additionally, Plaintiff's counsel has had to attend emergency hearings in other matters the past two days, and unable to devote as much time as originally anticipated to finalizing the various pre-trial documents. The focus of the parties' counsel has been to complete the exhibit lists and the Joint Pre-trial Order. In an effort to discuss and brief fully the remaining issues, and resolve as many disputed issues as possible, the parties' counsel respectfully request that the Court allow an additional week for the submission of their proposed joint voir dire, jury instructions, and verdict forms. CIV-04-0429-PHX-MHM PARTIES' STIPULATED REQUEST TO EXTEND TIME FOR FILING JOINT VOIR DIRE, JURY INSTRUCTIONS AND VERDICT FORM (Second Request) 1/

The parties have previous 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 123 Filed 06/01/2007 Page 1 of 2

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I, Suzanne M. Chynoweth, by signing below, certify pursuant to Paragraph II(C)(3),

2 District of Arizona ECF Administrative Policies and Procedures Manual (April 3, 2006) that the 3 content of this Stipulation is acceptable to Plaintiffs' counsel. 4 5 6 7 8 9 PATTERSON & ASSOCIATES 10 s/Rosval Patterson 11 12 13 CERTIFICATE OF SERVICE 14 I hereby certify that on June 1, 2007, I electronically transmitted the attached document 15 to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic 16 Filing to the following CM/ECF registrants: 17 Rosval A. Patterson 18 777 E. Thomas Rd. Phoenix, AZ 85014 19 s/S. Guerin ________________________________ 20 Office of the U.S. Attorney 21 22 23 24 25 26 27 28 2
Case 2:04-cv-00429-MHM Document 123 Filed 06/01/2007 Page 2 of 2

Respectfully submitted this 1st day of June, 2007. DANIEL G. KNAUSS United States Attorney District of Arizona s/Suzanne M. Chynoweth SUZANNE M. CHYNOWETH Assistant U.S. Attorney

ROSVAL PATTERSON Attorney for Plaintiff