Free Motion for Extension of Time - District Court of Arizona - Arizona

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Ernest Calderón (# 007677) Faith C. Klepper (# 018444) CALDERÓN LAW OFFICES 2020 N. Central Ave., Suite 1110 Phoenix, AZ 85004 Telephone: (602) 265-0004 Attorneys for Defendant IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA JOYCE A. CORRALES, Plaintiff, vs. CHASE BANKCARD SERVICES, INC., Defendant. STIPULATION TO EXTEND TIME TO FILE RESPONSE TO DEFENDANT MOTION FOR SANCTIONS AND REPLY TO PLAINTIFF'S RESPONSE TO MOTION FOR SUMMARY JUDGMENT No. CIV 02-2157-PHX-SRB

The parties, by and through undersigned counsel, hereby stipulate that Plaintiff will respond to Defendant's Motion for Sanctions and Defendant will reply to Plaintiff's Response in Opposition to the Motion for Summary Judgment ("Response") and Plaintiff's Separate Statement of Facts ("SSOF"), only after the Court rules on Defendant's currently pending Motion to Strike the Response and SSOF. At such time as the Court may rule on the Motion to Strike, the parties will have an additional 10 days to file the aforementioned pleadings, if

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necessary. Additionally, the parties request an expedited Rule 16 conference to address the
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issues pending before the court. RESPECTFULLY SUBMITTED this 19th day of July, 2006. CALDERÓN LAW OFFICES LAW OFFICE OF MARK BRINTON

By s/Faith C. Klepper Ernest Calderón Faith C. Klepper Attorneys for Defendant

By Mark Brinton Attorney for Plaintiff

Case 2:02-cv-02157-SRB

Document 79

Filed 07/19/2006

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ORIGINAL of the foregoing electronically filed this 19th day of July, 2006 with: Clerk of the Court United States District Court, District of Arizona 401 West Washington Phoenix, Arizona 85003 COPY of the foregoing mailed this 19th day of July, 2006 to: The Honorable Susan R. Bolton United States District Court 401 West Washington Phoenix, Arizona 85003 Mark Brinton Attorney at Law 1745 South Alma School Road, Suite 100 Mesa, Arizona 85210-3010 By s/Faith C. Klepper

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Case 2:02-cv-02157-SRB

Document 79

Filed 07/19/2006

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