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 and Defendants hereby stipulate to (or alternatively jointly move for) a brief extension of time (two weeks) for the filing of Plaintiff's brief in support of his attorneys fees request. The brief was scheduled to be filed this day, March 6, 2006. The requested extension would go to March 20, 2006. This extension is requested for the following two reasons: 1. Plaintiff's counsel has lost several days in preparation due to a septic tank CV03 2344 PHX FJM STIPULATION/JOINT MOTION TO EXTEND DEADLINE FOR FILING BRIEFS ON ATTORNEY'S FEES REQUEST

back up which flooded his home (including home office) with sewage from Thursday, March 2, 2006 through this date (March 6, 2006). The sewage damaged several of the Shaffer file folders and documents. It is anticipated that clean up will take several more days and may still result in permanent damage to certain client file materials. 2. The parties have, pursuant to their duty under the rules, met to discuss

attorney's fees. In the course of that discussion, it was anticipated that each party would Case 2:03-cv-02344-FJM Document 162 Filed 03/06/2006 Page 1 of 2

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provide the other additional information which might lead to an agreement on reasonable attorneys fees. Due to the intervening septic problems, Plaintiff's counsel has not be able to provide Defense counsel with the promised information. The parties would use some of the additional time requested to attempt to agree on reasonable attorneys fees. WHEREFORE, the parties stipulate/jointly move that the date for filing of Plaintiff's brief in support of his request for attorneys fees be extended to March 20, 2006. SUBMITTED this March 6, 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 GALLAGHER & KENNEDY

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

By: s/ Jay Zweig Jay Zweig 2575 E. Camelback Rd. Phoenix, AZ 85016-9225 Attorney for Defendants Copy of the foregoing electronically transmitted via the U.S. District Court's Electronic Case Filing System this March 6, 2006

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