Free Stipulation - District Court of Arizona - Arizona

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15

PAUL K. CHARLTON United States Attorney District of Arizona SUE A. KLEIN Assistant U.S. Attorney Arizona State Bar No. 11253 Two Renaissance Square 40 North Central Ave., Ste. 1200 Phoenix, Arizona 85004-4408 Telephone: (602) 514-7500 E-Mail: [email protected]

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America, Plaintiff, v. 192.019 Acres of Land, et al, Defendants. The United States and defendants, Glen G. Curtis, Sam Perricone and Louise Perricone, STIPULATION FOR MODIFICATION OF PRETRIAL SCHEDULE CIV-03-2006-PHX-SRB

16 hereby stipulate and jointly move for the entry of the attached Order to extend dates and to 17 modify the pretrial schedule in this case. The parties attempted to complete discovery by the 18 December 1, 2005, deadline. However, scheduling conflicts with expert witnesses prevented 19 this. The parties now have depositions of the government appraiser, landowner representative 20 and landowner appraiser set for February 22 - 23, March 2 and March 8, 2006, respectively. 21 Additionally, settlement conferences with Magistrate Judge Aspey are set for May 9, 2006. The 22 attorneys for the United States and the defendants further agree that the following modifications 23 should be made to the pretrial schedule and that such modifications will not prejudice either 24 party: 1. Completion of all discovery, including answers to interrogatories, production of 25 26 documents, depositions and requests to admit, and supplementation of all discovery, including 27 changes to expert witness opinions and disclosures required pursuant to 26(a)(3), Fed. R. Civ. P., 28 and disclosure of all exhibits and witnesses to be used at trial, be extended to March 31, 2006;

Case 2:03-cv-02006-SRB

Document 114

Filed 01/05/2006

Page 1 of 3

1 2

2. The filing of all dispositive motions be extended to April 28, 2006; The parties do not believe that extension of these deadlines will affect the deadlines for

3 motions in limine, the pretrial order, the pretrial conference or the trial date, which are set for 4 July and August of 2006. 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
2

Respectfully submitted this 5th day of January, 2006. PAUL K. CHARLTON United States Attorney District of Arizona

s/Sue A. Klein SUE A. KLEIN Assistant U. S. Attorney

s/John A. Weil JOHN A. WEIL Attorney for Defendants

Case 2:03-cv-02006-SRB

Document 114

Filed 01/05/2006

Page 2 of 3

1

I hereby certify that on January 5, 2006, I electronically transmitted the attached document

2 to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of 3 Electronic Filing to the following CM/ECF registrants: 4
John A. Weil

5 Weil & Weil
Attorneys at Law

6 1600 S. Fourth Ave., Ste. C
Yuma, Arizona 85364

7
s/Nancy Stotler

8
________________________

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
3

Case 2:03-cv-02006-SRB

Document 114

Filed 01/05/2006

Page 3 of 3