Free Stipulation - District Court of Arizona - Arizona

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Stephen G. Montoya (#011791) MONTOYA JIMENEZ, P.A.
The Great American Tower 3200 North Central Avenue, Ste. 2550 Phoenix, Arizona 85012 (602) 256-6718 (fax) 256-6667

[email protected] Attorney for Plaintiff

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IN THE UNITED STATES DISTRICT COURT
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FOR THE DISTRICT OF ARIZONA
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Monica Ortega-Guerin, plaintiff, vs.

No. CIV 04-0289-PHX-MHM Stipulation for an Extension of Time in Which Plaintiff has to Respond to Defendants' Rule 59 Motion for New Trial on Damages or Alternatively Request for Remittitur

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City of Phoenix, Frank Favela, and Frank Peralta, defendants.

Plaintiff's Response to Defendants' Rule 59 Motion for New Trial on Damages or
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Alternatively Request for Remittitur is presently due today, January 17, 2006.
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This afternoon at approximately 1:45 p.m., plaintiff's counsel finished a six-day
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jury trial on behalf of another client before the Honorable Lawrence O. Anderson of this
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Court in the case of Burnett v. Bottoms, et al., No. CV 03-1891-PHX-LOA. This trial
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understandably interfered with plaintiff's counsel's completion of Ms. Ortega's Response
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to Defendants' Rule 59 Motions.
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Accordingly, Plaintiff respectfully requests an extension of time in which to
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respond to Defendants' Rule 59 Motion for New Trial on Damages or Alternatively
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Case 2:04-cv-00289-MHM

Document 85

Filed 01/17/2006

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Request for Remittitur from Tuesday, January 17, 2006 to Wednesday, January 25, 2006. Plaintiff's counsel has conferred with Defendants' counsel, Mr. David Gaona, and he does not oppose this request. Dated the 17th day of January, 2006. MONTOYA JIMENEZ A Professional Association s/ Stephen G. Montoya Stephen G. Montoya 3200 North Central Avenue, Ste. 2550 Phoenix, Arizona 85012-2490 Attorney for Plaintiff

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Case 2:04-cv-00289-MHM

Document 85

Filed 01/17/2006

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CERTIFICATE OF SERVICE

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I hereby certify that on January 17, 2006, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: David F. Gaona Gaona Law Firm 3101 North Central Avenue, Suite 720 Phoenix, Arizona 85012 Attorney for Defendants

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I further certify that on January 18, 2006, the attached document was handdelivered to: The Honorable Mary H. Murguia United States District Court for the District of Arizona Sandra Day O'Connor United States Courthouse 401 West Washington Street Phoenix, Arizona 85003

s/ Stephen G. Montoya

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Case 2:04-cv-00289-MHM

Document 85

Filed 01/17/2006

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