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

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TERRY GODDARD Attorney General J. Randall Jue Assistant Attorney General State Bar No. 014816 1275 West Washington Phoenix, Arizona 85007-2926 Telephone: (602) 542-4951 Fax: (602) 542-7670 Attorneys for Defendants IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Andre Almond Dennison, Plaintiff, v. Conrad Luna, et al., Defendants. DEFENDANTS' MOTION FOR ENLARGEMENT OF TIME TO SUPPLEMENT THEIR DISCOVERY RESPONSES No. 03-CV-2373 PHX SRB (JI)

Defendants,1 through undersigned counsel, move for an enlargement of time to supplement their discovery responses pursuant to the Court's Order [Dkt. no. 99]. This motion is supported by the attached Memorandum of Points and Authorities. RESPECTFULLY SUBMITTED on this 9th day of December, 2005. TERRY GODDARD Attorney General

s/ J. Randall Jue J. RANDALL JUE Assistant Attorney General Attorneys for Defendants ///
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Luna, Stewart, James, Emore, Pinson, Hewitt, Nelson, Fridenmaker, Cooper, and

Schriro.
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MEMORANDUM OF POINTS AND AUTHORITIES After conducting two discovery conferences, the Court ordered the Defendants to supplement their discovery responses by December 9, 2005. [Dkt. no. 99.] The

Defendants have made a good faith effort to find any additional documentation pursuant to the Court's Order. However, the Defendants need additional time to draft supplemental responses due to Defense counsel's involvement with other pending matters. Counsel had oral argument before the Ninth Circuit on December 5, 2005, in Mulholland v. Holliday (02-CV-105), filed a Motion for Summary Judgment in Wussler v. Stewart (02-CV-1768), and had to prepare an answering brief for the Ninth Circuit in Pickett v. Stewart (02-CV1773). Consequently, the Defendants request that they be permitted to supplement their discovery responses by December 16, 2005. Rule 6(b) of the Federal Rules of Civil Procedure permits the Court for cause shown, in its discretion, to grant an appropriate extension of time to comply with the rules or an order of the Court. The Defendants contend that the reasons set forth above

constitute good cause for the Court to exercise its discretion. The Defendants are not trying to delay the timely resolution of this matter. RESPECTFULLY SUBMITTED on this 9th day of December, 2005. TERRY GODDARD Attorney General

s/ J. Randall Jue J. RANDALL JUE Assistant Attorney General Attorneys for Defendants

Original e-filed this 9th day of December, 2005, with: Clerk of the Court United States District Court District of Arizona 401 West Washington Phoenix, Arizona 85003

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1 COPY mailed on the same date to: 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 s/ C. Jordan Secretary to J. Randall Jue
IDS04-0294/RM G2004-20632 938175

Andre Almond Dennison, # 143931 ASPC ­ Lewis ­ Morey Unit P.O. Box 3300 Buckeye, Arizona 85326 Plaintiff Pro Per

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