Free Motion to Continue - District Court of Arizona - Arizona

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STEPTOE & JOHNSON LLP Collier Center 201 East Washington Street Suite 1600 Phoenix, Arizona 85004-2382 Telephone: (602) 257-5200 Facsimile: (602) 257-5299 Karl M. Tilleman (013435) P. Bruce Converse (005868) Janice K. Crawford (019042) Attorneys for Plaintiff UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA Northland Insurance Company, a Minnesota corporation, Plaintiff, vs. Correctional Medical Services, Inc., a Missouri corporation, Dr. Antonio DiMaano, Dr. Reynaldo Figueroa, Nurse Lorraine Lopez-Moreno, Nurse Trina Carrasco, Nurse Jacqueline Cornwell, and ABC Insurance Company, Defendants. Plaintiff Northland Insurance Company moves for a continuance of the time within which the parties may file a stipulation for dismissal for an additional 30 days. By minute entry dated March 9, 2006, this Court ordered that the case would be dismissed within 30 days, unless a stipulation for dismissal was filed within that period. The parties have diligently pursued the preparation of settlement documents during the period of time since that order, have finalized those settlement documents, and have sent the documents out for signature. In order to resolve all of the claims, at least two entities not currently parties to MOTION FOR CONTINUANCE OF DATE FOR DISMISSAL No. CV 04-347 PHX-FJM

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Case 2:04-cv-00347-FJM

Document 160

Filed 04/08/2006

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this action must sign releases, and the parties have as yet been unable to complete execution of the documents. The parties do not foresee any problem. However, in light of the circumstances, it has simply taken longer than anticipated to complete the execution of the documents. Accordingly, Northland requests that the court extend the time for the filing of a stipulation for dismissal for 30 days, through and including May 9, 2006. RESPECTFULLY SUBMITTED this 8th day of April, 2006. STEPTOE & JOHNSON LLP

By /s/ P. Bruce Converse Karl M. Tilleman P. Bruce Converse Janice K. Crawford 201 East Washington, Suite 1600 Phoenix, Arizona 85004 Attorneys for Plaintiff Northland Insurance Company

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Case 2:04-cv-00347-FJM Document 160 Filed 04/08/2006

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CERTIFICATE OF SERVICE I hereby certify that on the 8th day of April, 2006, I caused the attached document to be electronically transmitted to the Clerk' Office using the CM/ECF System for filing s and transmittal of a Notice of Electronic Filing to the Following CM/ECF Registrants: Stephen Paul Forrest, Esquire Holloway Odegard Forrest Kelly & Kasparek 3101 North Central Avenue, Suite 1200 Phoenix, Arizona 85012 Attorneys for Defendants Correctional Medical Services, Inc., Lorraine Lopez-Moreno, Trina Carrasco, and Jacqueline Cornwell

STEPTOE & JOHNSON LLP By /s/ P. Bruce Converse Karl M. Tilleman P. Bruce Converse Janice K. Crawford 201 East Washington, Suite 1600 Phoenix, Arizona 85004 Attorneys for Defendant

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Case 2:04-cv-00347-FJM Document 160 Filed 04/08/2006

Doc. #496124 v.1

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