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

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PLATTNER VERDERAME, P.C. 316 East Flower P. O. Box 36570 Phoenix, Arizona 85067-6570 (602) 266-2002 State Bar No. 00138600 Richard S. Plattner State Bar No. 019820 Attorneys for Plaintiff UNITED STATES DISTRICT COURT

7 DISTRICT OF ARIZONA 8 Michele Pettet, 9 Plaintiff, 10 v. 11 12 13 14 The parties hereby jointly move the Court to extend the expert disclosure 15 deadline for an additional sixty (60) days. This motion is supported by the accompanying 16 Memorandum of Points and Authorities attached hereto and incorporated herein by this 17 reference. This motion is made for good cause and not for any purpose of delay. 18 19 PLATTNER VERDERAME, P.C. 20 21 22 23 24 25 26 S/ Les S. Tuskai Attorneys for Defendant JONES, SKELTON & HOCHULI, P.L.C. S/ Richard S. Plattner Attorney for Plaintiff DATED this 16th day of August, 2005. Prudential Property Casualty Insurance Co., Defendant. JOINT MOTION TO EXTEND EXPERT DISCLOSURE DEADLINE (First Request for Extension) NO. CIV 04-0780-PHX-SMM

Case 2:04-cv-00780-SMM

Document 25

Filed 08/16/2005

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MEMO RANDUM OF POINTS AND AUTHORITIES Plaintiff's expert disclosure deadline in this case is currently set for August 19, 2005, and Defendants' deadline is thirty (30) days thereafter. On June 3, 2005, the Parties submitted a Stipulation to Extend Discovery Deadlines. On June 7, 2005, the Court granted an extension for non-expert discovery until December 2, 2005. However, the Parties' Stipulation and Proposed Order did not address the expert and rebuttal expert opinion deadlines, which was an oversight. Deposition of Plaintiff has been scheduled for the week of August 29, 2005; defense counsel is attempting to arrange deposition dates for Defendants' employees in September. Information gathered from these depositions is critical for the formation of expert opinions. The Parties respectfully request an extension of the disclosure deadlines for an additional sixty (60) days, or until October 19, 2005, for Plaintiff's expert disclosure deadline, December 19, 2005, for Defendants' expert disclosure deadline, and January 19, 2006, for rebuttal expert opinions. The proposed extension will not interfere with the time set for hearing, motion or trial, as no trial date has yet been set by this Court. However, the deadline for all dispositive motions is set for February 24, 2006, and the Final Pretrial Conference, in which a trial date will be selected, is set for March 26, 2006. RESPECTFULLY SUBMITTED this 16th day of August, 2005. PLATTNER VERDERAME, P.C.

S/ Richard S. Plattner Attorney for Plaintiff

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1516702_1

JONES SKELTON & HOCHULI S/ Les S. Tuskai Attorneys for Defendant COPY of the foregoing electronically filed with the Court this 16 th day of August, 2005.

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Case 2:04-cv-00780-SMM