Free Stipulation - District Court of Arizona - Arizona

1 2 3 40 North Center Street, Suite 200 4 Mesa, Arizona 85201 (480) 464-1111 5 Attorneys for Plaintiffs By: Michael R. Pruitt, No. 011792 Mark A. Shields, No. 018614 6 7 8 9 10 Connie Alms, a single woman, 11 Plaintiff, 12 vs. 13 AdvancePCS, a Delaware corporation, 14 n/k/a CaremarkRx, Inc., a Delaware corporation, 15 Defendant. 16 17 Plaintiff, Connie Alms, and Defendant, AdvancePCS, by and through their 18 undersigned counsel, stipulate and request the Court to enter the accompanying Order 19 extending the deadline for taking the deposition testimony of Plaintiff, Rick Wenben and 20 Gina Wise through and including October 31, 2005. The current deadline for taking these 21 deposition is set for October 3, 2005. Along with the extension of the deadline for the taking 22 of the three depositions, the parties stipulate and jointly request the Court to extend the 23 deadline for filing dispositive motions and motions in limine through and including January 24 6, 2006. The current deadline for filing dispositive motions and motions in limine is 25 December 1, 2005. 26
Case 2:04-cv-00332-JWS Document 47 Filed 08/19/2005 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Case No. CIV 04-0332 PHX JWS STIPULATION TO EXTEND DEADLINE FOR TAKING DEPOSITION TESTIMONY OF PLAINTIFF, RICK WENBEN AND GINA WISE AND FILING OF DISPOSITIVE MOTIONS AND MOTIONS IN LIMINE. (Fourth request)

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Due to counsel's trial schedule, the parties have been unable to arrange a suitable time

2 for the depositions of Plaintiff and Rick Wenben. Upon information and belief, the last 3 known address and phone number for Ms. Wise is no longer valid. This extension will allow 4 additional time to attempt to locate Ms. Wise for a deposition and for the parties to schedule 5 the depositions of Plaintiff and Rick Wenben. 6 This request for an extension of the deadline for taking the deposition testimony of

7 these three witnesses is made in good faith and is not for the purpose of delay or any other 8 inappropriate reason. The parties agree to participate in a discovery conference should the 9 court deem it necessary. 10 11 12 JACKSON WHITE 13 14 15 16 17 18 19 20 CERTIFICATE OF SERVICE s/ Michael R. Pruitt By: Michael R. Pruitt, Esq. 40 North Center Street, Suite 200 Mesa, Arizona 85201 Attorneys for the Plaintiff s/ Steven G. Biddle By: Steven G. Biddle, Esq. Rebecca Burnside, Esq. 2425 East Camelback Road, Suite 900 Phoenix, Arizona 85016 Attorneys for Defendant LITTLER MENDELSON DATED this 19th day of August, 2005.

I hereby certify that on August 19, 2005, I electronically transmitted the attached documents to the Clerk's Office using the CM/ECF System for filing and transmitted a 21 Notice of Electronic Filing to the following CM/ECF registrants: 22 Rebecca Burnside, Esq. 23 Steven Biddle, Esq. 24 25 26
Case 2:04-cv-00332-JWS Document 47 2 Filed 08/19/2005 Page 2 of 3

s/ Michael R. Pruitt Michael R. Pruitt

1 COPY of the foregoing mailed this 19th day of August, 2005, to: 2 Honorable John W. Sedwick 3 United States District Court 222 W. 7th Avenue, #4 4 Anchorage, AK 99513 5 6 By______________________________
F:\ABC\Alms\District\Stip.Extend.Disc.4.Alms.wpd

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Case 2:04-cv-00332-JWS Document 47 3 Filed 08/19/2005 Page 3 of 3