Free Motion for Extension of Time - 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 26 27 28

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

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Craig Tucker, plaintiff, vs. The City of Tempe, defendant.

No. CIV 03-1425-PHX-DGC Plaintiff's Motion for an Extension of Time in which to File Plaintiff's Memorandum in Support of Motion for Award of Attorney Fees

Plaintiff's Memorandum in Support his Motion for an Award of Attorney Fees is presently due on Monday, May 15, 2006. Plaintiffs' counsel is busy completing Court ordered depositions and preparing for a trial scheduled to commence on Tuesday, May 16, 2006 before the Honorable Robert C. Broomfield in the case of Madani, et al. v. BHVT Motors, Inc., No. CV 04-1897-PHX-RGC. Because Plaintiff's counsel has been completing Court ordered depositions and preparing for trial, Plaintiff respectfully requests a brief extension of time in which to file Plaintiff's Memorandum in Support of his Motion for an Award of Attorney Fees from May 15, 2006 to May 23, 2006. Plaintiff's counsel tried to confer with counsel for Defendant regarding this request, Ms. Marlene Pontrelli, but was informed by her office that she was unavailable until next week.

Case 2:03-cv-01425-DGC

Document 67

Filed 05/12/2006

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 26 27 28 s/ Stephen G. Montoya

Respectfully submitted this 12th 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 Plaintiff

I hereby certify that on May 12, 2006, I electronically transmitted the foregoing 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: Marlene A. Pontrelli Janis L. Bladine Kara L. Stanek Tempe City Attorney's Office P.O. Box 5002 Tempe, Arizona 85280 Attorneys for Defendants

I hereby certify that on May 15, 2006, I served the foregoing document by hand-delivery to the following: The Honorable David G. Campbell United States District Court for the District of Arizona Sandra Day O'Connor United States Courthouse 401 West Washington Street Phoenix, Arizona 85003

-2-

Case 2:03-cv-01425-DGC

Document 67

Filed 05/12/2006

Page 2 of 2