November 6, 2007 The Honorable Earl H. Carroll United States District Court Sandra Day O'Connor U.S. Courthouse, Suite 521 401 West Washington Street, SPC 48 Phoenix, AZ 85003-2151 RE: Notice of Plaintiffs' Intent to File Motion for Leave to Amend Complaint on Tuesday, November 27, 2007 in No. CV 04-0200-PHX-EHC.
Dear Judge Carroll: At the status conference on October 10, I informed you of the Plaintiffs' intent to seek leave to file an Amended Complaint within 30 days of the status conference. After making every effort to abide by that schedule, it has become clear that the Plaintiffs need additional time in order to ensure that every necessary Amendment is sought in the initial motion to amend and thus avoid additional motions to amend. Therefore, Plaintiffs intend to take an additional three weeks and file their Motion for Leave to Amend on Tuesday, November 27, 2007. I spoke with Ms. Mary O'Grady, counsel for the state Defendants, and she had no objection to the additional time. I also spoke with Mr. Timothy Hogan, counsel for the Intervenor-Defendants, and he had no objection to the proposed November 27, 2007 filing date. The Plaintiffs are committed to resolving this case expeditiously and to timely completing discovery after the Complaint is answered. Very Sincerely, s/ Timothy D. Keller Timothy D. Keller Counsel for Plaintiffs cc: Mary O'Grady and Tanja Karin Shipman, Counsel for Defendants Timothy M. Hogan, Counsel for Intervenor-Defendants Deborah Goldberg, Counsel for Intervenor-Defendants
Case 2:04-cv-00200-EHC
Document 52
Filed 11/06/2007
Page 1 of 1