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

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RICHARD J. HARRIS LAW OFFICES, P.C .
304 MACY DR. ROSWELL, GA 30076 (770) 643-1606 (770) 643-1442 fax [email protected]

Richard J. Harris ­ #013859 Attorney for Plaintiff IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Matthew Shaffer, Plaintiff, v. State of Arizona Citizens Clean Election Commission; Colleen Connor and Chad Jacobs; husband and wife; and Jessica Funkhouser and Lindy Funkouser, husband and wife; John Does I-X; Jane Does I-X Defendants. Plaintiff moves for a brief extension of time (two weeks) for the filing of Plaintiff's brief in support of his attorneys fees request. The court granted a prior extension based upon the parties' joint motion and scheduled Plaintiff's brief to be filed March 20, 2006. Plaintiff urges the court to grant a second two week extension until April 3, 2006. There is good cause for another brief extension. Plaintiff's counsel has been attending to his seven year old son's serious medical condition which became a medical emergency on March 8, 2006.1 His doctor has scheduled him for medical procedures for today, March 14, 2006, for March 15, 2006 and for surgery on March 20, 2006. CV03 2344 PHX FJM MOTION TO EXTEND DEADLINE FOR FILING BRIEFS ON ATTORNEY'S FEES REQUEST (Second Request)

The undersigned's son (Christian Harris) was admitted to the emergency room to treat congenital kidney defects on the very date of the court's order granting the original two week extension. Case 2:03-cv-02344-FJM Document 165 Filed 03/14/2006 Page 1 of 2

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Plaintiff's counsel does not anticipate having the time to adequately brief the attorney's fees by the deadline for filing and therefore requests another two week extension (or until April 3, 2006). Plaintiff has attempted to contact Defense counsel to stipulate or join in this motion, but has not been able to reach Mr. Zweig. Plaintiff hereby invites Defense counsel to stipulate to (or jointly move for) the extension. WHEREFORE, the Plaintiff moves that the date for filing of Plaintiff's brief in support of his request for attorneys fees be extended to April 3, 2006. SUBMITTED this March 14, 2006. R ICHARD J. H ARRIS L AW O FFICES, P.C. By: s/Richard J. Harris Richard J. Harris 304 Macy Dr. Roswell, GA 30076 Copy of the foregoing electronically transmitted via the U.S. District Court's Electronic Case Filing System this March 14, 2006 s/Richard J. Harris

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R ICH ARD J. H ARRIS L AW O FFICES , P .C .
Shaffer\pleadings\post trial\Motion for Extension to File Brief on Attorneys Fees 002

2 Case 2:03-cv-02344-FJM Document 165 Filed 03/14/2006 Page 2 of 2