Free Response to Motion - District Court of Arizona - Arizona

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Terry Goddard Attorney General Michele L. Forney, Bar No. 019775 Assistant Attorney General 1275 W. Washington Phoenix, Arizona 85007-2997 Telephone: (602) 542-4951 Fax: (602) 542-7670 E-mail: [email protected] Attorneys for Defendants

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Case 2:03-cv-02159-ROS-JRI Document 169 Filed 06/20/2008 Page 1 of 2

Timothy Lee Ward, No. CV 03-2159 PHX ROS (JRI) Plaintiff, v. Sgt. Carr, et al., Defendants. Defendants Carr and Stewart respond to Plaintiff's Motion to Expand Time (dkt. 165). Plaintiff requested additional time to comply with the Court's order dated March 26, 2008 (dkt. 133), in which the Court ordered the following: IT IS FURTHER ORDERED that within fifteen days of the service of their responses to Plaintiff's additional requests for production authorized herein, Defendants shall contact Plaintiff in person or by telephone to discuss any remaining discovery disputes. IT IS FURTHER ORDERED that within ten days of the completion of such conference among the parties, Plaintiff shall file a notice advising the Court of any additional unresolved discovery disputes, and that the discovery conference is ready to be set. The Court will thereafter set a time for the discovery conference. (Dkt. 133 at 4.) Defendants agree that undersigned counsel contacted Plaintiff within fifteen days of serving Defendants' responses to the additional requests for production, DEFENDANTS' RESPONSE TO PLAINTIFF'S MOTION TO EXPAND TIME (DKT. 165)

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that Plaintiff and undersigned counsel discussed the remaining discovery disputes and that they agreed to enter into a stipulation to submit various materials to the Court for in camera review. Defendants further agree that because of faxing and mailing time, the parties were unable to finalize the stipulation until today. Therefore, Defendants agree and join in Plaintiff's request for additional time to comply with the Court's order regarding the stipulation only. The stipulation requesting in camera review is being filed contemporaneously with this response. RESPECTFULLY SUBMITTED this 20th day of June, 2008. Terry Goddard Attorney General s/Michele L. Forney Michele L. Forney Assistant Attorney General Attorneys for Defendants Original e-filed this 20th day of June, 2008, with: Clerk of the Court United States District Court District of Arizona 401 West Washington Street, SPC 1 Phoenix, AZ 85003-2118 Copy mailed the same date to:

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Case 2:03-cv-02159-ROS-JRI

Timothy Lee Ward, #148256 ASPC - Eyman - SMU I P.O. Box 4000 Florence, AZ 85232 s/Colleen S. Jordan Secretary to: Michele L. Forney IDS04-0306/RSK:G04-20640 #230154

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Document 169 Filed 06/20/2008 Page 2 of 2