Free Motion to Continue - District Court of Arizona - Arizona

1 James M. McGee, Esq. 2 Attorney at Law Arizona State Bar No. 011931 3 P.O. Box 460 Cottonwood, Arizona 86326 4 Telephone: 928.639.4747 FAX: 928.639.2190 5 6 Attorney for Defendants/Third Party Plaintiffs 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 COMES NOW Home Mortgage, Inc., (HMI) an Arizona corporation formerly conducting CATHLEEN CHANNEL; THERESA WHARRY; STACIE HANSON; MONIQUE NICHOLS, PLAINTIFFS, v. HOME MORTGAGE, INC., an Arizona Corporation conducting business in Arizona; CARL BROWN; MOLLY BROWN; DOES 1-10; XYZ CORPORATIONS; BLACK PARTNERSHIPS; DEFENDANTS/THIRD PARTY PLAINTIFFS, v. LAWRENCE GREGORY BROWN, John and Jane Does I-X; JANE DOE BROWN; XYZ CORPORATIONS; BLACK AND WHITE PARTNERSHIPS I-X, THIRD PARTY DEFENDANTS. CAUSE NO.: CIV2003100PHXROS MOTION TO CONTINUE STATUS CONFERENCE OF JUNE 15, 2007 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

27 business in Arizona; Carl I. Brown and Molly Brown, and files this their Motion to Continue 28 Status Conference of June 15, 2007 for the following reasons: Case 2:03-cv-00100-ROS-MEA Document 142 Filed 06/05/2007 Page 1 of 4

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1.

HMI,

or

its

Counsel

never

received

any

courtesy

phone

call

for

scheduling/calendaring purposes or for anything, and then now, an apparent Motion to Continue that Status Conference of June 14, 2007 to June 15, 2007 without any consultation as well. Attorney Shields has known or should have known that

undersigned Counsel has been of record since at least May 1, 2007 and any pending pleadings, motions, etc., should have been conveyed or at least a courtesy phone call placed to advise of same. Surprisingly, even the Court itself FAXed an Order changing the date of the Status Conference to the Defendants/Third Party Plaintiffs themselves. It should not be a surprise to anyone that Internet service in rural areas such as Cottonwood and the Verde Valley is scattered at best, but generally poor overall. 2. Counsel undersigned in the meantime had scheduled certain U.S. Military obligations at the Marine Corps Air Station, Miramar, California on June 14 and 15,

15 16 17 18 19 20 21 22 Status Conference presently scheduled for June 15, 2007 be continued to a date when all 23 24 25 26 27 Case 2:03-cv-00100-ROS-MEA parties and Counsel can be present in the jurisdiction. DATED AND RESPECTFULLY SUBMITTED this 4th day of June, 2007.
James M. McGee
Digitally signed by James M. McGee DN: cn=James M. McGee, o=Law Office, ou, [email protected], c=US Date: 2007.06.05 11:34:51 -07'00'

2007. 3. Counsel undersigned also previously planned for almost a year, to attend the high school graduation of HIS ONLY CHILD, AND ONLY SON, at Torrey Pines High School on June 15, 2007 in San Diego, California. See, attached. Counsel will therefore be out of the District of Arizona on that day, as well. FOR THE ABOVE STATED REASONS, Defendants/Third Party Plaintiffs request that the

James M. McGee Counsel for Defendants/Third Party Plaintiffs Document 142 2 Filed 06/05/2007 Page 2 of 4

Original of the foregoing 1 e-filed and mailed this 4th 2 day of June, 2007 to: 3 Court Counsel for Channel, et al. 4 Client 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Case 2:03-cv-00100-ROS-MEA Document 142 3 Filed 06/05/2007 Page 3 of 4

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James M. McGee, Esq. Attorney at Law Arizona State Bar No. 011931 P.O. Box 460 Cottonwood, Arizona 86326 Telephone: 928.639.4747 FAX: 928.639.2190 Attorney for Defendants/Third Party Plaintiffs IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA CATHLEEN CHANNEL; THERESA WHARRY; STACIE HANSON; MONIQUE NICHOLS, PLAINTIFFS, v. HOME MORTGAGE, INC., an Arizona Corporation conducting business in Arizona; CARL BROWN; MOLLY BROWN; DOES 1-10; XYZ CORPORATIONS; BLACK PARTNERSHIPS; DEFENDANTS/THIRD PARTY PLAINTIFFS, v. LAWRENCE GREGORY BROWN, John and Jane Does I-X; JANE DOE BROWN; XYZ CORPORATIONS; BLACK AND WHITE PARTNERSHIPS I-X, THIRD PARTY DEFENDANTS. Pursuant to the Defendants' Motion and for good cause shown, CAUSE NO.: CIV2003100PHXROS ORDER TO CONTINUE STATUS CONFERENCE OF JUNE 15, 2007

24 IT IS HEREBY ORDERED vacating the June 15, 2007 status conference and 25 26 27 Case 2:03-cv-00100-ROS-MEA ________________________________________ Roslyn O. Silver United States District Judge Document 142 4 Filed 06/05/2007 Page 4 of 4 rescheduling said status conference to __________, 2007 at __________ __.m.