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

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TERRY GODDARD Attorney General MISTY D. GUILLE Assistant Attorney General State Bar No. 020830 1275 West Washington Phoenix, Arizona 85007-2926 Telephone: (602) 542-4951 Fax: (602) 542-7670 [email protected] Attorneys for Defendant IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA GILBERT KOSTISHAK aka DAKOTA LIVOLSI, Plaintiff, v. ARIZONA DEPARTMENT OF CORRECTIONS, et al. Defendants. No. CV 03-2031-PCT-DGC (ECV) UNOPPOSED MOTION FOR ENLARGEMENT OF DISPOSITIVE MOTION DEADLINE (Second Request)

Defendant Arizona Department of Corrections, by and through undersigned counsel, requests a 60-day extension to file dispositive motions. The current deadline for dispositive motions is September 15, 2005, and the extended date would be November 14, 2005. The reason for this request is that the parties are making a good faith effort to reach an agreement that fully resolves this matter. Additionally, undersigned counsel must obtain approval for any proposed settlement, which typically takes more than two weeks. This request is made in good faith and the extension is not sought for purposes of delay. On September 7, 2005, undersigned counsel spoke telephonically to Plaintiff Kostishak, who had no objection to this extension request.

Case 2:03-cv-02031-DGC-ECV

Document 32

Filed 09/07/2005

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Therefore, the Defendant respectfully requests the Court grant an extension until November 14, 2005, for the parties to file dispositive motions. RESPECTFULLY SUBMITTED this 7th day of September, 2005. TERRY GODDARD Attorney General /s Misty D. Guille MISTY D. GUILLE Assistant Attorney General Attorneys for Defendant

COPY of the foregoing and COPY of Notice of Electronic Filing mailed the same date to: Gilbert Kostishak, ADC # 110968 ASPC-Yuma, Cocopah ­ Tent 5-03 P.O. Box 13005 Yuma, AZ 85366-3005 Plaintiff Pro Per /s Misty D. Guille
IDS04-0336/RM G2004-20730 923210

Case 2:03-cv-02031-DGC-ECV

Document 32

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Filed 09/07/2005

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