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

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18

Marshall A. Martin, Esq. #010055 LAW OFFICES OF MARSHALL A. MARTIN 8930 E. Raintree Drive, Suite 100 Scottsdale, AZ 85260 Attorney for Plaintiff UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA 1) Bobbie M. Golden, et al., Plaintiffs v. ) ) ) ) ) ) ) ) ) ) ) )

No. CIV-04-0320-PHX-PGR PLAINTIFFS MOTION FOR EXTENSION OF TIME TO RESPOND

2) Arizona Department of Administration, et al.,

Defendant.

Plaintiffs, by and through their undersigned counsel, hereby move this Court for an additional thirty (30) days to respond to Defendants' three separate Motions

19 20 21 22 23 24 25 26 27 28

for Summary Judgment, all of which were filed on August 5, 2005. Each motion is 25 or more pages in length with 150 or more pages of attachments including lengthy separate Statements of Fact. Plaintiffs need to respond to each of these three motions simultaneously. Undersigned counsel for Plaintiffs has other professional commitments including a trial the week of August 22, 2005 which would make it extremely difficult to review all of the evidence in this case and prepare the appropriate

Case 2:04-cv-00320-PGR

Document 91

Filed 08/10/2005

Page 1 of 3

1 2

response and separate statement of facts for each of the three motions for summary judgment. For these reasons, undersigned counsel is requesting an additional thirty

3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

(30) days in which to respond, which would not adversely affect the Defendants in this matter or other deadlines in the case. A Form of Order has been lodged herewith. Respectfully submitted this 10th day of August, 2005. LAW OFFICES OF MARSHALL A. MARTIN

/s/ Marshall A. Martin Marshall A. Martin 8930 E. Raintree Dr., Suite 100 Scottsdale, AZ 85260 (480) 444-9980 Attorney for Plaintiff COPY of the foregoing e-mailed this 10th day of August, 2005, to: Michael M. Walker, Esq. Assistant Attorneys General Office of the Attorney General 1275 West Washington Street Phoenix, Arizona 85007-2926 Attorneys for Defendants Arizona Department of Administration and Capital Police Rebecca J. Herbst, Esq. JONES, SKELTON & HOCHULI, P.L.C. 2901 North Central Avenue, Suite 800 Phoenix, Arizona 85012 Attorneys for Defendant Corcoran

Case 2:04-cv-00320-PGR

Document 91

Filed 08/10/2005

Page 2 of 3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Steven G. Biddle, Esq. LITTLER MENDELSON 2425 East Camelback Road Suite 900 Phoenix, Arizona 85016 Attorneys for Defendants Staubitz /s/ Marshall A. Martin

Case 2:04-cv-00320-PGR

Document 91

Filed 08/10/2005

Page 3 of 3