Free Motion to Expedite - District Court of Arizona - Arizona

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Law Office of James Burr Shields 382 East Palm Lane Phoenix, Arizona 85004-1531 (602) 307-0780 (Office) (602) 307-0784 (Facsimile)
James Burr Shields II, State Bar #011711 John A. Conley, State Bar #016429 Blake Simms, State Bar #021595 Attorneys for Plaintiff

IN THE UNITED STATES DISTRICT COURT IN AND FOR THE STATE OF ARIZONA

) ) ) ) ) Plaintiffs, ) ) vs. ) ) Home Mortgage, Inc., an ) Arizona corporation conducting ) business in Arizona, ) Carl Brown; ) Molly Brown; ) Greg Brown; ) Jane Doe Brown; ) ) Defendants. ) ____________________________)

Cathleen Channel, Theresa Wharry, Stacie Hanson, Monique Nichols,

Case No. CIV 2003-0100 PHX ROS PLAINTIFFS' REQUEST FOR EXPEDITED BRIEFING SCHEDULE AND RULING RE REQUEST FOR RECONSIDERATION

Plaintiffs, by and through counsel undersigned, hereby respectfully request that the Court order an expedited briefing schedule in regards to their request for reconsideration submitted on August 7, 2007, as document no. 161. As set forth in this brief, it is the Plaintiffs' position that they possess overwhelming and clear cut evidence that the corporate veil between Defendants, Carl and Molly Brown and Home Mortgage, Inc., must be pierced. Again, one of the main representations by the Browns which led the Court to deny Plaintiffs' motion for summary judgment has now been completely invalidated. The trial of this case is set forth September 18, 2007. Because of the evidence set forth in Plaintiffs' request for reconsideration, it is respectfully submitted that there is no need for such a trial. In the event that the Court agrees, an expedited ruling would save
Document 163 Filed 08/09/2007 Page 1 of 2

Case 2:03-cv-00100-ROS-MEA

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Plaintiffs thousands of dollars in attorneys' fees in connection with preparing for such a trial. For the above reasons, it is respectfully requested that the Court require Defendants to address the substance of Plaintiffs' request for reconsideration on or before August 24, 2007 and that Plaintiffs be permitted to reply by August 29, 2007. Then, it is respectfully requested that the Court issue a ruling by September 11, 2007. Plaintiffs, and their counsel, are acutely aware of the Court's tremendously busy schedule. However, an award of summary judgment in Plaintiffs' favor, which seems unquestionably warranted given the information in Plaintiffs' brief and request for reconsideration, will, obviously, free up the Court's schedule considerably during the week of September 17th. RESPECTFULLY SUBMITTED this 9th day of August, 2007. LAW OFFICE OF JAMES BURR SHIELDS

____s/ James Burr Shields_______________ James Burr Shields Blake Simms Attorneys for Plaintiffs CERTIFICATE OF SERVICE I hereby certify that on the 9th day of August, 2007, I electronically submitted 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: James M. McGee, Esq. P.O. Box 460 Cottonwood, Arizona 86326 [email protected] Attorney for Defendants ____s/ Gail Ivey___________________

Case 2:03-cv-00100-ROS-MEA

-2Document 163

Filed 08/09/2007

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