Free Stipulation - District Court of Arizona - Arizona

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LAW OFFICES One Arizona Center, 400 E. Van Buren Phoenix, Arizona 85004-2202 (602) 382-6000

Joseph G. Adams (#018210) Jennifer Axel (#023883) SNELL & WILMER L.L.P. One Arizona Center 400 E. Van Buren Phoenix, AZ 85004-2202 Telephone: (602) 382-6000 Facsimile: (602) 382-6070 Email: [email protected] Email: [email protected] Attorneys for Plaintiff/Counterdefendant Great American Duck Races, Inc. IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

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Great American Duck Races, Inc. d/b/a/ Great American Merchandising & Events, an Arizona corporation, Plaintiff/Counterdefendant, v.

No. CIV-04-0317 PHX JWS JOINT STIPULATION FOR ORDER EXTENDING PRETRIAL DEADLINES (Assigned to Hon. John W. Sedwick)

Snell & Wilmer L.L.P.

Associated Leisure Products, Inc., dba Aqua EZ, a Georgia corporation, Defendant/Counterclaimant. And related counterclaims.

(Third Request)

Plaintiff/Counterdefendant Great American Duck Races, Inc., doing business as Great American Merchandise and Events ("GAME"), and Defendant/Counterclaimant Associated Leisure Products, Inc., doing business as Aqua EZ ("Aqua EZ"), jointly request that the Court extend the pretrial deadlines in this case. In a scheduling order dated October 31, 2005, the Court established various pretrial deadlines in this case, including a deadline of January 30, 2006 to complete discovery and a deadline of February 28, 2006 for the filing of dispositive motions. However, Snell & Wilmer recently took over as counsel of record for GAME in December 2005. Since that time, the parties have been engaged in settlement discussions in an attempt to resolve the

Case 2:04-cv-00317-JWS

Document 45

Filed 01/30/2006

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LAW OFFICES One Arizona Center, 400 E. Van Buren Phoenix, Arizona 85004-2202 (602) 382-6000

dispute underlying this action. Although both parties are optimistic that settlement may be possible, they need additional time to complete discovery if settlement negotiations are unsuccessful. In light of this continuing dialogue and recent substitution of new counsel, the parties jointly request that the Court extend both the discovery deadline and the dispositive motion deadline by an additional ninety (90) days to allow time for the settlement discussions to continue and to allow discovery to conclude in the event that a settlement is not reached. In particular, the parties propose that the discovery cut-off be extended to May 1, 2006 and that the dispositive motion deadline be extended to May 29, 2006. GAME has submitted a proposed form of Order contemporaneously with this stipulation. DATED this 30th day of January, 2006. SNELL & WILMER L.L.P.

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Snell & Wilmer L.L.P.

By

s/ Joseph G. Adams Joseph G. Adams Jennifer Axel One Arizona Center 400 E. Van Buren Phoenix, AZ 85004-2202 Attorneys for Great American Duck Races, Inc.
LEWIS & ROCA, LLP

By

s/ Sean D. Garrison Sean D. Garrison Emily Bayton 40 N. Central Avenue Phoenix, AZ 85004-4429 Attorneys for Associated Leisure Products, Inc.

1785261.2

Case 2:04-cv-00317-JWS

Document 45 - 2 -Filed 01/30/2006

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