Free Stipulation - District Court of Arizona - Arizona

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Janice H. Moore ­ 006180 Tracey N. Fernandes ­ 016482

FADELL, CHENEY & BURT, P.L.L.C. 1601 North Seventh Street, Suite 400 Phoenix, Arizona 85006
Telephone: (602) 257-7909 E-mail: [email protected]

Attorneys for Defendant JSB Holdings, Inc. IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Connie B. Pappas, Plaintiff, vs. J.S.B. Holdings, Inc., an Arizona corporation, d.b.a. R&D Specialty/Manco, Defendant. No. CIV 03-1449-PHX-PGR STIPULATION TO EXTEND PRETRIAL DEADLINES AND TO CONTINUE THE PRETRIAL CONFERENCE (First Request)

Defendant JSB Holdings, Inc., dba R&D Specialty/Manco ("Defendant"), and Plaintiff Connie B. Pappas, by and through their undersigned counsel, hereby agree and stipulate to extend for 60 days the pretrial dates/deadlines contained in the Court's Order filed September 29, 2005. This request for a 60-day extension applies to the current deadline of November 18, 2005, for submitting the Joint Pretrial Statement, joint settlement letter and any motions in limine, and the Pretrial Conference currently set for Monday, December 12, 2005. Defendant's counsel is facing a personal family emergency related to the illness of her spouse. The scheduled surgery, along with the expected rehabilitation period, will necessitate Defendant's counsel being absent from the office since she is the only care provider. Accordingly, the parties propose the following dates/deadlines: the deadline to submit the Joint Pretrial Statement, joint settlement letter, and any motions in limine be extended to January 17, 2006, and the Pretrial Conference reset for Monday, February 13, 2006, or as soon thereafter as is convenient for the Court.

Case 2:03-cv-01449-PGR

Document 56

Filed 11/07/2005

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This request is made with the agreement of counsel for the parties, in good faith and not for the purpose of delay. RESPECTFULLY SUBMITTED this 7th day of November, 2005. FADELL, CHENEY & BURT, P.L.L.C. By s/ Janice H. Moore Janice H. Moore 1601 North Seventh Street, Suite 400 Phoenix, Arizona 85006 Attorneys for Defendant JSB

LAW OFFICE OF LYNN M. LANEY, JR. By _s/ Lynn M. Laney, Jr.____ Lynn M. Laney, Jr. 934 West McDowell Road Phoenix, Arizona 85007-1730 Attorney for Plaintiff Connie Pappas

I certify that on the 7th day of November, 2005, I electronically transmitted the 18 attached document to the Clerk's Office 19 using the CM/ECF System for filing and e-mailed a copy of same to:
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The Honorable Paul G. Rosenblatt 22 United States District Court Sandra Day O'Connor U.S. Courthouse 23 Suite 621 24 401 West Washington Street, SPC 56 Phoenix, Arizona 85003-2156
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By s/ Tracey Fernandes

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Case 2:03-cv-01449-PGR Document 56 Filed 11/07/2005 Page 2 of 2