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

Mark F. Brinton (SBA 7674) Law Office of Mark F. Brinton 1745 South Alma School Road, Suite 100 Mesa, AZ 85210-3010 (480) 756-2256 Counsel for Plaintiff

UNITED STATES DISTRICT COURT FOR THE DISTRICT COURT OF ARIZONA Joyce Corrales, CV 2002-2157 PHX SRB Plaintiff, v. Chase Bankcard Services, Inc., a Delaware corporation, (First Request) Defendant. 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 June 5) by 21 days (to Monday, June 26) for Plaintiff to file her Response to Defendant's Motion for Summary Judgment. The basis for this Motion is manifold: Plaintiff's counsel, a sole practitioner, has been occupied drafting 1) an appeal to the Ninth Circuit Court of Appeals which is due on June 5; 2) an appeal to the Arizona Court of Appeals; 3) a mediation memorandum and preparing for a mediation hearing scheduled for June 8 and June 15, respectively; and 4) has been occupied preparing for four depositions set for June 7, two of which are his client's fact MOTION FOR EXTENSION OF TIME TO FILE RESPONSE

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witnesses. And finally, the undersigned will be out of the State of Arizona from early June 1 through June 5 in order attend a nephew's graduation from the University of Michigan Medical School on June 2 and another nephew's graduation from the University of Washington School of Dentistry on June 3. In view of these five factors, the undersigned needs the subject extension. Moreover, Defense counsel Faith C. Klepper has informed the undersigned that she does not oppose this Motion. RESPECTFULLY SUBMITTED THIS 31st of May 2006, Law Office of Mark F. Brinton /s/ Mark F. Brinoton Mark F. Brinton Counsel for Plaintiff Plutt I hereby certify that I electronically transmitted the foregoing document and the attached Order to the Clerk's Office using the CM/ECF system for filing and transmittal of a Notice of Electronic Filing to the CM/ECF registrants on this 31st day of May 2006. /s/ Mark F. Brinton

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

Joyce Corrales, Plaintiff, vs. Chase Bankcard Services, Inc., Defendant. ______________________________)

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No. CV 2002 - 2157 PHX SRB ORDER

Plaintiff's Motion for Extension of Time to File Response having been presented to the Court, and good cause appearing, IT IS HEREBY ORDERED that the time for Plaintiff to file a Response to Defendant's Motion for Summary Judgment shall be extended from 5 June 2006 to 26 June 2006. DATED THIS ____ day of June 2006,

__________________________________ The Honorable Susan R. Bolton Judge of the United States District Court

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