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 through their undersigned counsel hereby request that the Court extend the deadlines in its February 12, 2007 order by one week, from April 2, 2007 until April 16, 2007. Good cause for this request exists because of the heavy litigation schedule and work load for Defendant's counsel. Since January 10, 2007, five days after the court denied the parties' summary judgment motions, AUSA Chynoweth has participated in 21 depositions involving two wrongful death cases assigned after the retirement of civil defensive AUSAs Hair and Mayfield, who have not been replaced. [See e.g. Notice of Substitution of Counsel in: Aranda v. U.S. CV05-04231, Doc. #. 44 and Matthieu v. U.S., (Wrongful Death), CV06-01101, Doc. # 28; see also deposition notices.] Undersigned counsel for defendant has also been assigned to handle numerous other cases in addition to an already heavy case load, including title VII cases, from AUSAs Hair and Mayfield. Plaintiff's counsel provided drafts of the pre-trial order and other documents Wednesday afternoon, but AUSA Chynoweth has been in four depositions since then. CIV-04-0429-PHX-MHM PARTIES' STIPULATED REQUEST TO EXEND TIME RE: PRE-TRIAL DEADLINES

Case 2:04-cv-00429-MHM

Document 109

Filed 03/30/2007

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In any event, the parties have not yet had an opportunity to coordinate and discuss

2 preliminary drafts of the pre-trial documents, and will be unable to do so. It is therefore requested 3 that the court extend the deadlines as requested. 4 I, Suzanne M. Chynoweth, by signing below, certify pursuant to Paragraph II(C)(3),

5 District of Arizona ECF Administrative Policies and Procedures Manual (April 3, 2006) that the 6 content of this Stipulation is acceptable to Plaintiffs' counsel. 7 8 9 10 11 12 13 14 15 16 17 18 CERTIFICATE OF SERVICE I hereby certify that on March 30, 2007, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice 19 of Electronic Filing to the following CM/ECF registrants: 20 Rosval A. Patterson 21 777 E. Thomas Rd. Phoenix, AZ 85014 22 s/S. Guerin 23 ________________________________ Office of the U.S. Attorney 24 25 26 27 28 2
Case 2:04-cv-00429-MHM Document 109 Filed 03/30/2007 Page 2 of 2

Respectfully submitted this 30th day of March, 2007. DANIEL G. KNAUSS United States Attorney District of Arizona s/Suzanne M. Chynoweth SUZANNE M. CHYNOWETH Assistant U.S. Attorney PATTERSON & ASSOCIATES s/Rosval Patterson ROSVAL PATTERSON Attorney for Plaintiff