Free Motion for Extension of Time to File Answer - District Court of Arizona - Arizona

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TERRY GODDARD ATTORNEY GENERAL (FIRM STATE BAR NO. 14000) CARI M. MCCONEGHY-HARRIS ASSISTANT ATTORNEY GENERAL CRIMINAL APPEALS SECTION 1275 W. WASHINGTON PHOENIX, ARIZONA 85007B2997 TELEPHONE: (602) 542B4686 (STATE BAR NUMBER 020572) E-MAIL: [email protected] ATTORNEYS FOR RESPONDENTS

UNITED STATES DISTRICT COURT
DISTRICT OF ARIZONA
GREGORY ALIK PIKE, fka GREGORY WATERMAN,
Petitioner,

CIV 02­2368­PHX­JWS (DKD) MOTION FOR EXTENSION OF TIME TO FILE ANSWER TO PETITIONER'S PETITION FOR WRIT OF HABEAS CORPUS (Second Request)

-vsDora B. Schriro, et al.,
Respondents.

Respondents respectfully request that this Court extend the time within

17 which Respondents may file their Answer to Petitioner's Petition for Writ of 18 Habeas Corpus. The Answer is currently due on March 26, 2007, and Respondents 19 move for a 40­day extension until Monday, May 7, 2007. 20 Undersigned counsel moves for this extension, because (1) undersigned 21 counsel was only recently re-assigned to this case after an absence from the office, 22 (2) Petitioner did properly raise several of his constitutional claims in the Arizona 23 courts, so an answer on the merits will be necessary, and (3) Respondents have 24 begun preparing the answer, but the record in this case is extensive and contains 25 more than 22 transcripts from the trial court proceedings which require more time 26 for proper analysis as well as for copying and scanning as exhibits. 27 28
Case 2:02-cv-02368-JWS Document 114 1 Filed 03/20/2007 Page 1 of 2

Respondents recognize that this case has been pending for a long time and

1 Petitioner must certainly be anxious for its completion. Respondents aver that this 2 extension is absolutely necessary, however, and that counsel is preparing the case 3 as quickly as possible. Undersigned counsel apologizes to this Court and Petitioner 4 for this unavoidable delay. Counsel avows that no further extension requests will 5 be made. 6 7 8 9 10 11 12 13 14 15 16 17 I hereby certify that on this 20th day of March, 2007, I electronically transmitted the attached document to the Clerk's Office using the ECF System for filing and 18 deposited for mailing the attached document and the Notice of Electronic Filing to the following, non-registered participant of the ECF System: 19 GREGORY ALIK PIKE, #111126 20 fka GREGORY WATERMAN ASPC-Tucson-Santa Rita Unit 21 P.O. Box 24406 Tucson, Arizona 85734 22 Petitioner, Pro Se 23 24 s/L. Lopez 25 CRM95­0248 127585 26 27 28
Case 2:02-cv-02368-JWS Document 114 2 Filed 03/20/2007 Page 2 of 2
S/CARI M. MCCONEGHY-HARRIS ASSISTANT ATTORNEY GENERAL ATTORNEYS FOR RESPONDENTS

DATED this 20th day of March, 2007. RESPECTFULLY SUBMITTED, TERRY GODDARD ATTORNEY GENERAL