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

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Terry Goddard Arizona Attorney General Michael E. Gottfried Assistant Attorney General State Bar No. 010623 1275 West Washington Street Phoenix, Arizona 85007-2997 Phone: (602) 542-7693 Fax: (602) 542-7670 E-mail: [email protected] Attorneys for Defendants UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA ALBERT W. DELEON, No. CV 04-0446 PHX JAT (JRI) Plaintiff, v. DORA B. SCHRIRO; et al., Defendants. UNOPPOSED MOTION TO EXTEND DEADLINE

Defendants Reyes, Avalos, Paredez, and Ramon, by undersigned counsel, hereby move to extend the deadline for filing the Joint Proposed Pretrial Statement, Stipulated-To Statement of the Case, Joint Proposed Voir Dire, Joint Proposed Jury Instructions, and Separate Forms of Verdict through November 21, 2007. Given that the Plaintiff is in incarcerated, it is more difficult to jointly prepare these documents. Plaintiff is The

cooperating, but this additional time is necessary to prepare these documents.

undersigned represents that he has spoken to Plaintiff and he has no objection to this extension and joins in this Motion. Wherefore, it is respectfully requested that the Court extend the deadline to file the Joint Proposed Pretrial Statement, Stipulated-To Statement of the Case, Joint Proposed

#93033 ­ Unopposed Motion to Extend Deadline

Case 2:04-cv-00446-JAT

Document 262

Filed 11/15/2007

Page 1 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Voir Dire, Joint Proposed Jury Instructions, and Separate Forms of Verdict through November 21, 2007. RESPECTFULLY SUBMITTED this 15th day of November, 2007. Terry Goddard Arizona Attorney General

s/Michael E. Gottfried Michael E. Gottfried Assistant Attorney General Attorneys for Defendants Original E-mailed this 15th day of November, 2007, to: The Honorable James A. Teilborg UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA 401 West Washington Street, SPC 51 Phoenix, AZ 85003 Copy mailed this 16th day of November, 2007, to: Albert W. DeLeon, #P269470 MARICOPA COUNTY LOWER BUCKEYE JAIL 3250 West Lower Buckeye Road Phoenix, Arizona 85009 s/ C. Jordan Secretary to Michael E. Gottfried IDS04-0271/RM# G03-03830

#93033 ­ Unopposed Motion to Extend Deadline

2
Document 262 Filed 11/15/2007 Page 2 of 2

Case 2:04-cv-00446-JAT