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

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DANIEL G. KNAUSS United States Attorney District of Arizona SUE A. KLEIN Assistant U.S. Attorney Arizona State Bar No. 11253 Two Renaissance Square 40 N. Central Avenue, Ste. 1200 Phoenix, Arizona 85004-4408 Telephone: (602) 514-7500 E-Mail: [email protected]

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America, Plaintiff, CIV-04-0626-PHX-JWS v. John B. Knight, Jr.; Robert D. Brown; National Petroleum Marketing, Inc.; Sunwest Express, Inc.; and Navajo Trails, Inc., Defendants. The plaintiff, United States of America, and defendants hereby request this Court to MOTION TO EXTEND TIME TO RESPOND AND REPLY TO MOTION FOR PARTIAL SUMMARY JUDGMENT

18 extend the time to respond and reply to the pending Motion for Partial Summary Judgment until 19 October 31, 2007. The parties are engaged in meaningful settlement discussions and believe it 20 is in the best interest of all parties to continue to work on an agreeable resolution to this matter. 21 The United States is in the process of drafting and circulating a Consent Decree which is 22 necessary to resolve environmental matters. 23 The attorney for the United States has discussed this motion with the attorney for 24 defendants John B. Knight, Jr.; National Petroleum Marketing, Inc.; Sunwest Express, Inc.; and 25 Navajo Trails, Inc., who has no objection. 26 The attorney for the United States attempted to each the attorney for Robert Brown by 27 phone and e-mail, but was unable to reach Mr. Brown's attorney. 28

Case 2:04-cv-00626-JWS

Document 51

Filed 08/21/2007

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WHEREFORE, the United States respectfully requests the Court grant the motion and

2 extend the time for response and replies to the pending Motion for Partial Summary Judgment 3 until October 31, 2007. 4 Respectfully submitted this 21st day of August, 2007. 5 DANIEL G. KNAUSS United States Attorney 6 District of Arizona 7 s/Sue A. Klein 8 9 10 11 12 13 14 CERTIFICATION I hereby certify that on August 21, 2007, I electronically transmitted the attached SUE A. KLEIN Assistant U.S. Attorney

15 document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice 16 of Electronic Filing to the following CM/ECF registrants: 17 Ronald Meyer 18 One Columbus Plaza 19 Suite 1050 20
3636 North Central Avenue Phoenix, Arizona 85012 Attorney at Law

21 Harold D. Burr, Jr. 22 23 24 25 26 27 28
s/N. Stotler

Burr and Associates, P.C. Eighteen East University Drive, Ste. 206 Mesa, Arizona 85201

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Case 2:04-cv-00626-JWS

Document 51

Filed 08/21/2007

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