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

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LAW OFFICE OF ROBERT M. GREGORY, P.C. Robert M. Gregory, State Bar No. 021805 1930 S. Alma School Road, Suite A-115 Mesa, Arizona 85210 Telephone: (480) 839-4711 Facsimile: (480) 452-1753 [email protected] Attorney for Plaintiffs

IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA ROBERT GANT and BETTY GANT, husband and wife,
) ) ) Plaintiffs, ) ) vs. ) ) ROGER VANDERPOOL, Sheriff of Pinal ) County; PINAL COUNTY, a political ) subdivision; JOHN DOES, I­X; JANE ) DOES, I­X; ABC-XYZ CORPORATIONS I- ) X; BLACK AND WHITE PARTNERSHIPS ) I-X, jointly and severally, ) ) Defendants. ) ) )

Case No. CV 03-2077-PHX-EHC PLAINTIFFS' REQUEST FOR EXTENSION

(Assigned to the Honorable Earl H. Carroll)

Plaintiffs Robert Gant and Betty Gant, through undersigned counsel, respectfully submit this Request for Extension, in which Plaintiffs seek additional time within which to prepare for trial, including time to exchange trial materials with Defendant. This Request for Extension is necessitated by a serious illness that has stricken Plaintiffs' counsel, Robert Gregory, and his family, which will require Plaintiffs' counsel to receive ongoing medical treatments over the next several months. Plaintiffs' counsel has discussed this matter with Defendants' counsel, Georgia Staton, who does not object to Plaintiffs' Request for Extension. The parties had a telephonic conference
Case 2:03-cv-02077-EHC Document 86 Filed 02/08/2006 Page 1 of 2

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with Court staff and Court staff indicated that the Court may be willing to continue the trial in this matter to July 11, 2006. Plaintiffs respectfully request, therefore, that the Court enter an order continuing deadlines in this matter, as follows: 1) Exchange of trial exhibits between the parties ­ by June 2, 2006; 2) File joint pretrial statement, voir dire, jury instructions, and motions in limine ­ by June 16, 2006; 3) Final Pretrial Conference ­ at such time as the Court deems appropriate; and 4) Trial ­ July 11, 2006, at 9:00 a.m. RESPECTFULLY SUBMITTED this _7th_ day of February, 2006. LAW OFFICE OF ROBERT M. GREGORY, P.C. By: _s/Robert M. Gregory___________________ Robert M. Gregory Attorney for Plaintiffs

ORIGINAL of the foregoing filed this _7th_ day of February, 2006, with: Clerk of the Court United States District Court District of Arizona 401 W. Washington Avenue Phoenix, AZ 85003

_s/Robert Gregory____________

Case 2:03-cv-02077-EHC

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