Free Motion to Continue - District Court of Arizona - Arizona

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

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.

) Case No.: CV-03-1987-PHX-JAT ) ) ) UNOPPOSED MOTION TO CONTINUE ) PRETRIAL DATES ) ) ) ) )

The Plaintiff, by and through undersigned counsel, hereby files this Unopposed Motion to Continue the Pretrial Conference, which is currently scheduled for November 7, 2005, at 11.00 a.m. in this division, and for a continuance of the Pretrial Conference deadlines, for an additional 60 days. A continuance is requested due to the fact that Plaintiff's counsel was only recently retained and needs time to familiarize herself with the case. In addition, counsel have conferred telephonically regarding the merits of the case and agree that a settlement conference would be beneficial and Defendant's counsel does not oppose Plaintiff's request for a continuance. A continuance for 60 days would allow time for the parties to engage in meaningful settlement negotiations. WHEREFORE, the Plaintiff respectfully requests that the Pretrial Conference scheduled in this matter for November 7, 2005, at 11:00 a.m., and the associated pretrial conference deadlines, including the September 23, 2005, deadline for submission of the Proposed Final Pretrial Form of Order, should

Case 2:03-cv-01987-JAT

-1 Document 57 Filed 09/22/2005

Page 1 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

be continued for at least sixty days. Counsel for Defendant has indicated in writing that he does not oppose this motion. RESPECTFULLY SUBMITTED this 22nd day of September, 2005. WILSON-GOODMAN & FONG, P.C. __/s/ Angela M. Wilson-Goodman Angela M. Wilson-Goodman 538 S. Gilbert Road, Suite 101 Gilbert, Arizona 85296 Attorney for Plaintiff

ORIGINAL of the foregoing filed this 22nd day of September, 2005, with: Clerk of Court United States District Court District of Arizona - Phoenix Division Sandra Day O'Connor U.S. Courthouse, Suite 130 401 West Washington Street, SPC 1 Phoenix, AZ 85003-2118 COPIES of the foregoing e-mailed/delivered this 22nd day of September, 2005 to: The Honorable James A. Teilborg District Court Judge Sandra Day O'Connor U.S. Courthouse, Suite 523 401 W. Washington Street, SPC 51 Phoenix, AZ 85003-2154 Ronald J. Stolkin FENNEMORE CRAIG, P.C. 3003 N. Central Ave., Suite 2600 Phoenix, Arizona 85012-2913 Attorney for Defendant __Kim Johnson

Case 2:03-cv-01987-JAT

-2 Document 57 Filed 09/22/2005

Page 2 of 2