Free Stipulation - District Court of Arizona - Arizona

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ARBETMAN LAW OFFICE, P.C. JEFFREY F. ARBETMAN State Bar No. 005380 349 North 4 th Avenue Phoenix, Arizona 85003 (602) 265-1770 Attorney for Plaintiff

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2. 3. NOW COMES, the Plaintiff, Thomas D. McCaffrey ("McCaffrey"), by and through his attorney, Jeffrey F. Arbetman, and the Defendants John Snow and Michael Chertoff, by and through their attorney John Mayfield, Assistant U.S. Attorney and hereby stipulate, upon court approval, to extend the time for disclosure of expert witnesses under Rule 16, Federal Rules of Civil Procedure as follows: 1. Disclosure by Plaintiff shall be extended from March 3, 2006 to April 1, 2006; Defendants to not intend to call a rebuttal expert; and, The granting of this extension will not prejudice either party and have no effect on any other Rule 16 deadline. The reason for this stipulation is that plaintiff's counsel is a sole practioner. His legal secretary has not been at work for most of the last three months and plaintiff's Defendants. vs. John Snow, Secretary of the Treasury, and, Michael Chertoff, Director of the Department of Homeland Security, IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Thomas D. McCaffrey, Plaintiff, No.CV-04-0701-PHX-SMM STIPULATION TO EXTEND DEADLINE FOR DISCLOSURE OF EXPERT WITNESSES (First Request)

Case 2:04-cv-00701-SMM

Document 19

Filed 03/20/2006

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counsel has not been able to engage the expert by the deadline. DATED this 17 th day of March, 2006. ARBETMAN LAW OFFICE, P.C.

___s/__________________________________ Jeffrey F. Arbetman 349 N. 4 th Avenue Phoenix, Arizona 85003 Attorney for Plaintiff ASSISTANT U.S. ATTORNEY

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ___s/___________________________ By: Eva Lindsay Clerk, U.S. District Court District of Arizona 230 North First Avenue Phoenix, Arizona 85025 Original of the foregoing filed this 17th day of March, 2006, with ___s/___________________________________ John R. Mayfield Two Renaissance Square 40 North Central Avenue, Suite 1200 Phoenix, AZ 85004-4408 Attorney for Defendant

Case 2:04-cv-00701-SMM

2 Document 19

Filed 03/20/2006

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