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

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1 James W. Field MAR 0 6 ZUU6
P.O. Box 248 0 ZW y I Q_ F m“__ ___ _
2 saiame, Az. 85348 Q;g,;, ‘*T
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4 IN THE UNITED STATES DISTRICT COURT
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6 FOR THE DISTRICT OF ARIZONA
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8 James W. Field et. al. , ) Case No.: CV03-2214-PHX-SRB
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9 Plaintiff, ) PLAINTIFFS AFFADAVIT & NOTICE TO
) THE COURT THAT SOME AFFADAVITS
10 vs. ) ARE CURRENTLY UNAVAILABLE &
) NEED FOR ADDITIONAL TIME
11 La Paz County et. al. , ) PURSUANT TO RULE 56(f)
)
12 Defendant )

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14 Comes now Plaintiff mentioned above to notice the Court & APS Defendants, of the fact, at
i . . 15 this time AFFADIVATTS are unavailable in opposition to defendants claim concerning the
A ‘ 16 conditions of Utilities service on the date electrical power was terminated without notice to plaintiff ’s
17 property.
‘ 18 Additionally AFFADIVATTS are presently unavailable to support Plaintiffs claim Licensed
` 19 electricians worked for Wickenburg Pump and Electrical. Further that Wickenburg Pump &
2U Electrical employees did perform electrical work on plaintiffs property, as set forth in plaintiffs
21 statement of facts in support of denial of APS motion for Judgment on Pleadings / Motion for
22 Summary Judgment.
23 Plaintiff estimates the need of an additional 30 days in which to attempt to track down former
24 employees of Wickenburg Pump and Electrical to secure their AFFADIVATTS, that indeed they
25 performed the work indicated in plaintiff ’s statement of facts. Plaintiff also recently has discovered
Case 2:O3—cv—O2214—SFlB Document 1531r Filed O3/06/2006 Page 1 of 2

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1 the need to certify his exhibits attached to the statement of facts referred to in this motion, however
2 feels this can also be accomplished within the 30 days requested.
3 Plaintiff on personal knowledge says the work performed by Wickenburg Pump and Electrical
4 on plaintiff’s property mentioned in Plaintiffs statement of facts was performed by an Licensed
5 electrician employed by Wickenburg Pump and Electrical t
6 This request is made in good faith and not for reason to increase the cost of responding to
7 plaintiffs claims nor to unnecessarily delay the resolution of this matter, but in the interests of a fair
8 and just determination of the conflict on its merits as is favored in the United States Federal District
9 Court.
10 Under penalty of perjury, I declare that I have examined the above statements made by me
; 11 and by my personal knowledge all are true and correct. I further certify I am competent and will
_ 12 testify to the facts contained within this affidavit if called upon to do so.
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~ James W. Field ' ate
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16 Sworn and Subscribed before me this L day of mmt 2006.
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20 My Commission Expires EE; gE,:.w_ Mmm
mms 07I31/07
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Case 2:03-cv-02214-SRB

Document 153

Filed 03/06/2006

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Case 2:03-cv-02214-SRB

Document 153

Filed 03/06/2006

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