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

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Stephen G. Montoya (#011791) MONTOYA JIMENEZ, P.A. The Great American Tower 3200 North Central Avenue, Ste. 2550 Phoenix, Arizona 85012 (602) 256-6718 (fax) 256-6667 [email protected] Attorney for Plaintiff

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IN THE UNITED STATES DISTRICT COURT
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FOR THE DISTRICT OF ARIZONA
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Patrice Jerome, plaintiff, vs. Midway Holdings, Inc., Midway Auto Team, Midway Infiniti, Midway Nissan, Midway GMC, Midway Buick, Midway Pontiac, and Midway Chevrolet, defendants.

No. CV 03-1913-PHX MHM Plaintiff's Motion for an Extension of Time in Which to Respond to Defendant's Motion for Partial Reconsideration

In accordance with this Court's Minute Order of Tuesday, May 22, 2007, Plaintiff's Response to Defendants' Motion for Partial Reconsideration is due on Thursday, May 31, 2007. In light of the intervening holiday weekend, Plaintiff's counsel had only five judicial days in which to respond to the Motion--well less than half of the time (ten days plus, three days for mailing) that would have otherwise been provided for a response under Local Rule 7.2(c). Plaintiff's counsel had previously scheduled plans over the holiday weekend and has been busy in both depositions and two settlement conferences in other matters

Case 2:03-cv-01913-MHM

Document 82

Filed 05/31/2007

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during the five-day response period and has thus been unable to finalize Plaintiff's Response to Defendant's Motion for Reconsideration. Because Plaintiff's counsel is presently in a deposition, he has been unable to confer with counsel for Defendant, Ms. Stephanie K. Osteen, regarding this request. Accordingly, Plaintiff respectfully requests an extension of time in which to respond to Defendant's Motion for Partial Reconsideration from Thursday, May 31, 2007, to Thursday, June 7, 2007. Dated the 31st day of May 2007. MONTOYA JIMENEZ A Professional Association

Stephen G. Montoya

Stephen G. Montoya 3200 North Central Avenue, Ste. 2550 Phoenix, Arizona 85012-2490 Attorney for Plaintiff

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Case 2:03-cv-01913-MHM

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I certify that on May 31, 2007, 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 Electronic Filing 3 to the following CM/ECF registrants:
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Stephanie K. Osteen Akin Gump Strauss Hauer & Feld LLP 5 1700 Pacific Avenue Suite 4100 Dallas, Texas 75201 6 Attorneys for Defendants
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The Honorable Mary H. Murguia United States District Court for the District of Arizona 8 Sandra Day O'Connor United States Courthouse 401 West Washington Street 9 Phoenix, Arizona 85003
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Stephen G. Montoya
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Case 2:03-cv-01913-MHM

Document 82

Filed 05/31/2007

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