Free Motion for Extension of Time to File Answer - District Court of Arizona - Arizona

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TERRY GODDARD A TTORNEY GENERAL ROBERT J. GORMAN A SSISTANT A TTORNEY GENERAL CAPITAL LITIGATION SECTION 400 W. CONGRESS, S­315 TUCSON, A RIZONA 85701­1367 TELEPHONE : (520) 628­6520 (STATE BAR 012728) A TTORNEYS FOR RESPONDENTS

UNITED STATES DISTRICT COURT
DISTRICT OF ARIZONA
STEVEN CRAIG JAMES, PETITIONER , ­vs­ DORA B. SCHRIRO, et. al, RESPONDENTS. CV 00-1118-PHX-NVW MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO PETITIONER'S MERITS MEMORANDUM

Respondents respectfully request an extension of approximately 45 days, until September 25, 2007, to respond to Petitioner's Merits Memorandum--said response is currently due on August 10, 2007. This is Respondents' second request for an extension of time, and counsel for Petitioner, Mr. Douglas Gerlach, and Mr. Gary Lowenthal, have no objection. This extension is necessitated by the fact that during the last 4 months undersigned counsel's case load has increased greatly due to the medical-leaveof-absence of a co-worker, e.g., the added workload included preparing for and handling a week-long evidentiary hearing concerning the psychological condition of a capital habeas petitioner from early childhood to the time of the offense. Briefing on that matter is due in approximately two weeks.

Case 2:00-cv-01118-NVW

Document 121

Filed 07/13/2007

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This extension is requested so that an adequate response to the Merits Memorandum can be prepared and is made in good faith and not to delay these proceedings. DATED this 13th day of July, 2007. Respectfully submitted, TERRY GODDARD ATTORNEY GENERAL
S/ROBERT J. GORMAN ASSISTANT ATTORNEY GENERAL

ATTORNEYS FOR RESPONDENTS

Case 2:00-cv-01118-NVW

Document 121

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Filed 07/13/2007

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CERTIFICATE OF SERVICE

I hereby certify that on July 13, 2007, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and 3 transmittal of a Notice of Electronic Filing to the following CM/ECF registrant: Gary T. Lowenthal Arizona State University College of Law 5 P.O. Box 877906 Tempe, AZ 85287-7906
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Douglas Gerlach JENNINGS, STROUSS & SALMON, P.L.C. The Collier Center, 11th Floor 8 201 E. Washington Street Phoenix, Arizona 85004-2385
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Attorneys for PETITIONER s/ ROBERT J. GORMAN

CRM86-0529 meritsmot-ext

Filed 07/13/2007

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