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 FOR THE DISTRICT OF ARIZONA Patrice Jerome, plaintiff, vs. Midway Holdings, Inc., et al., defendants.

No. CV 03 1913 PHX MHM Plaintiff's Motion for an Extension of Time in which to Respond to Defendant's Motion for Summary Judgment (First Request)

Plaintiff's Response to Defendant's Motion for Summary Judgment is presently due on May 3, 2006. Plaintiff's counsel has been completing discovery (including taking out-of-state depositions) and representing a client in a settlement conferences in two other matters pending in the District of Arizona. Although Plaintiff's Response in Opposition to Defendant's Motion for Summary Judgment is near completion, Plaintiff's counsel's responsibilities in these two other matters have significantly reduced the time in which Plaintiff's counsel has had to responsibly finalize the papers opposing Defendant's Motion for Summary Judgment. Plaintiff's counsel has attempted to confer with Defendant's counsel, Ms. Stephanie Osteen, regarding this Motion, but was unable to discuss the request with her. Accordingly, Plaintiff respectfully requests an extension of time in which to respond to Defendant's Motion for Summary Judgment from May 3, 2006 to May 10, 2006.

Case 2:03-cv-01913-MHM

Document 71

Filed 05/04/2006

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Dated the 3rd day of May 2006. MONTOYA JIMENEZ A Professional Association s/ Stephen G. Montoya Stephen G. Montoya 3200 North Central Avenue, Ste. 2550 Phoenix, Arizona 85012-2490 Attorney for Plaintiffs

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Case 2:03-cv-01913-MHM

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CERTIFICATE OF SERVICE I hereby certify that on May 3, 2006, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: Stephanie K. Osteen Akin Gump Strauss Hauer & Feld LLP 1700 Pacific Avenue, Suite 4100 Dallas, Texas75201 Attorney for Defendants



I further certify that on May 4, 2006, the attached document was hand-delivered to: The Honorable Mary H. Murguia United States District Court for the District of Arizona Sandra Day O'Connor United States Courthouse 401 West Washington Street Phoenix, Arizona 85003

s/ Stephen G. Montoya

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Case 2:03-cv-01913-MHM

Document 71

Filed 05/04/2006

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