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

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Angela M. Wilson-Goodman State Bar No. 017558 WILSON-GOODMAN & FONG, P.C. 538 S. Gilbert Road, Suite 101 Gilbert, Arizona 85296 (480) 503-9217 Fax: (480) 503-9219 Attorneys for Plaintiff IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

MARY CSANYI, Plaintiff, vs. REGIS CORPORATION; SUPER CUTS, Defendants.

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Case No.: CV-03-1987-PHX-JAT JOINT MOTION TO EXTEND TIME TO FILE PROPOSED FINAL PRETRIAL FORM OF ORDER AND FINDINGS OF FACT AND CONCLUSIONS OF LAW

The Parties, by and through counsel undersigned, hereby jointly move this Court to extend the time to file their Proposed Final Pretrial Form of Order and Findings of Fact and Conclusions of Law until Wednesday, December 14, 2005, based upon the following. Specifically, the Parties have been working on the Proposed Final Pretrial Form of Order, exchanging emails and faxes regarding their respective positions this week, but during a telephone conference this afternoon to finalize the Proposed Final Pretrial Form of Order for lodging with the court, counsel realized they had been working off of two different versions of the Proposed Order and there was not one document that contained all of the information of both parties. In addition, Mr. Stolkin is flying out of state first thing tomorrow morning (Friday, December 9, 2005) to attend the funeral of a family friend, and it will be difficult for counsel to

Case 2:03-cv-01987-JAT

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Filed 12/08/2005

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finalize the Proposed Final Pretrial Form of Order in time for filing with the court on Friday, December 9th. WHEREFORE, the undersigned counsel respectfully request that this Court grant this Joint Motion to Extend the Time to File the Proposed Final Pretrial Form of Order and Findings of Fact and Conclusions of Law until Wednesday, December 14, 2005. RESPECTFULLY SUBMITTED this 8th day of December, 2005. FENNEMORE CRAIG, P.C. WILSON-GOODMAN & FONG, P.C.

/s Ronald J. Stolkin Ronald J. Stolkin Attorney for Defendant

s/ Angela M. Wilson-Goodman Angela M. Wilson-Goodman Attorney for Plaintiff

CERTIFICATE OF SERVICE I hereby certify that on the 8th day of December, 2005, I electronically transmitted the attached Motion to Extend Time to File Proposed Final Form of Order and Findings of Fact and Conclusions of Law to the U.S. District Court Clerk's office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: [email protected] [email protected] I hereby certify that on the 8th day of December, 2005, I served the attached by mail on the following Motion to Extend Time to File Proposed Final Form of Order and Findings of Fact and Conclusions of Law, who is a registered participant in the CM/ECF System, but requested a paper copy: The Honorable James A. Teilborg United States District Judge Sandra Day O'Connor U.S. Courthouse, Suite 523 401 West Washington Street, SPC 51 Phoenix, AZ 85003-2154 /s/ Kim Johnson

Case 2:03-cv-01987-JAT

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Filed 12/08/2005

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