Free Motion for Miscellaneous Relief - District Court of Arizona - Arizona

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GAIL GIANASI NATALE Arizona State Bar #010389 817 North Second Street Phoenix, AZ 85004 602-258-1778 Attorney for Petitioner

UNITED STATES DISTRICT COURT
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DISTRICT OF ARIZONA
6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 COMES NOW Petitioner CURTIS GRAYLIN SIMMONS, by and through counsel undersigned, and respectfully asks this Court for permission to Reply to Respondents' Response to Petitioner's Motion to Stay. Reasons are that until the Response was filed vs. DORA SCHRIRO, et al., Respondents. CURTIS GRAYLIN G. SIMMONS, Petitioner, PETITIONER'S REQUEST FOR PERMISSION TO REPLY TO RESPONDENTS' RESPONSE TO PETITIONER'S MOTION TO STAY D.C. No. CV 03-2172-PHX-NVW

Respondents had led Petitioner (and counsel) to believe that they did not object to a continuance of this Court's stay. Instead,

as they candidly admit, Respondents have reversed their position without notice. Under these circumstances, in the interest of justice, fairness and due process, Mr. Simmons requests an opportunity to Reply. He further asks this Court for a reasonable deadline by

which to Reply.

Case 2:03-cv-02172-NVW

Document 55

Filed 07/12/2007

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RESPECTFULLY SUBMITTED this 12th day of July, 2007. s/Gail Gianasi Natale GAIL GIANASI NATALE Attorney for Petitioner I hereby certify that on July 12, 2007, I electronically transmitted the attached document to the Clerk's Office using CM/ECF.

COPIES of the foregoing mailed 8 this 12th day of July, 2007, to: 9 The Honorable Neil V. Wake United States District Court 10 Sandra Day O'Connor U.S. Courthouse,Suite 524 401 West Washington Street, SPC 52 11 Phoenix, AZ 85003 12 Curtis Graylin Simmons, #35849 ASPC--Douglas, Gila Unit 13 P.O. Box 5003 Douglas, AZ 85608 14 s/Anita Jundy 15 16 17 18 19 20 21 22 23 24 25 26 2

Case 2:03-cv-02172-NVW

Document 55

Filed 07/12/2007

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