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

Mark F. Brinton (SBA 7674) Law Offices of Mark F. Brinton 1745 South Alma School Road, Suite 100 Mesa, AZ 85210-3010 (480) 756-2256 Counsel for Plaintiff Joyce Corrales IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT COURT OF ARIZONA Joyce Corrales, CV 02 - 02157 PHX - SRB Plaintiff, vs. Chase Bankcard Services, Inc. Defendant UNOPPOSED MOTION FOR EXTENSION TO RESPOND TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT (Second Request)

Plaintiff Joyce Corrales, through her undersigned counsel and pursuant to Rule 6(b), Federal Rules of Civil Procedure, and LRCiv 7.3 ( c), hereby moves to extend the due date (from today June 26) by four days (to Friday, June 30) for Plaintiff to file her Response to Defendant's Motion for Summary Judgment. The basis for this Motion is the undersigned's unexpected necessity to appear as counsel of record on 10 June 2006 on behalf of plaintiff in the case of Dlugajczyk v. Ourvacationstore.com, CV 04 - 2683 PHX LOA, wherein Plaintiff's deposition is scheduled for tomorrow, June 27, together with witness Jeri B. Greenberg, and five additional depositions set for

Case 2:02-cv-02157-SRB

Document 60

Filed 06/26/2006

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Thursday, June 29, in the same case. Plaintiff's counsel regrets this additional request, but as a sole practitioner under these exigent circumstances, four days more is a necessity. Moreover, Defense counsel has graciously informed the undersigned that she does not oppose this Motion. Accordingly, Plaintiff respectfully requests the Court to grant her Motion for Extension to Respond to Defendant's Motion for Summary Judgment. DATED THIS 26day of June 2006 Law Office of Mark F. Brinton By /s/ Mark F. Brinton Mark F. Brinton Counsel for Plaintiff Corrales I hereby certify that on the 26nd day of June 2006, I electronically transmitted the foregoing document to the Clerk's office using the CM/ECF System. /s/ Mark F. Brinton

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Case 2:02-cv-02157-SRB

Document 60

Filed 06/26/2006

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