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

1 TERRY GODDARD ATTORNEY GENERAL 2 WANDA E. HOFMANN (014805) 3 Assistant Attorney General 177 North Church Avenue, Suite 1105 4 Tucson, Arizona 85701-1114 (520) 628-6044 · Fax (520) 628-6050 5 [email protected] 6 Attorneys for Defendants 7 8 9 10 11 12 13 14 15 Defendants. 16 17 Defendants Dodge, Dolce, Larsen, Schriro, Pierce, Thelen, Rabideau, Walker and v. CARL B. DODGE; T. DOLCE; C. LARSEN; SANDRA WALKER; DORA SCHRIRO; KELLY PIERCE; J. THELEN; J. RABIDEAU; BRITTON, IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA CHARLES McMANUS, Plaintiff, DEFENDANTS' UNOPPOSED MOTION TO ENLARGE FILING DEADLINE FOR JOINT DISCOVERY PLANNING REPORT No. CV03-2327 PHX-MHM (JI)

18 Britton, with Plaintiff's approval, request the Court enlarge the deadline for them to file 19 their Joint Discovery Planning Report 30 days until Monday, September 12, 2005 for the 20 reasons explained below. Fed. R. Civ. P. 6(b). The Report is currently due on August 11, 21 2005. 22 The Plaintiff and undersigned counsel met telephonically on August 2, 2005 to

23 coordinate drafting their Joint Discovery Planning Report. Plaintiff has received the 24 preliminary draft report that counsel has forwarded to him and will need time to complete 25 and return to counsel via mail his portion of the report. Additionally, Plaintiff has a pre26 trial conference scheduled for August 19, 2005 in U.S. District Court in Phoenix on

Case 2:03-cv-02327-MHM-JRI

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1 another case and he must devote time to preparing that case. Counsel for the Defendants 2 will be out of the office after today until August 15, after which time she will again confer 3 with Plaintiff to finalize the report and mail it to him for his signature. The parties 4 anticipate that they will need 30 days beyond the scheduled August 11 deadline to 5 complete and file the report. 6 WHEREFORE, Defendants, with Plaintiff's approval, request the Court enlarge the

7 deadline by which they must file their Joint Discovery Planning Report until September 8 12, 2005. 9 10 11 12 13 14 15 COPY of the foregoing mailed day of August, 2005 to: this 16 17 Charles McManus, #79938 ASPC-Eyman, Meadows Unit 18 P.O. Box 3300 Florence, AZ 85232 19 20 Secretary, Attorney General's Office
IDS05-0022 / 916957

RESPECTFULLY SUBMITTED this

day of August, 2005. TERRY GODDARD ATTORNEY GENERAL

WANDA E. HOFMANN Assistant Attorney General Attorneys for Defendants

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