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

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Mishka L. Marshall (#016641) MARSHALL LAW GROUP, P.C. 777 East Thomas Road, Suite 210 Phoenix, AZ 85014 Telephone: 602/274-7873 Facsimile: 602/274-8207 Attorney for Plaintiff

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

KESORN HENDERSON Case No. CV 04 0754 PHX JAT Plaintiff, V. GUARDSMARK, LLC, a Delaware corporation doing business in Arizona; GUARDSMARK, INC. a Delaware corporation doing business in Arizona;
JOHN and JANE DOES I-X; BLACK CORPORATION I-X, WHITE LIMITED LIABILITY COMPANIES I-X,

PLAINTIFF'S MOTION FOR EXTENSION OF TIME IN WHICH TO RESPOND TO DEFENDANT'S MOTION FOR PARTIAL SUMMARY JUDGMENT (First Request)

Defendants.

Plaintiff Kesorn Henderson, through counsel undersigned, respectfully requests an extension of time in which to respond to Defendant's Motion for Partial Summary Judgment. Plaintiff requests a three week extension, to October 16, 2006, in which to file a response to Defendant's motion. The requested extension is necessary because of the litigation schedule of Plaintiff's counsel. Counsel has been out of town conducting depositions for much of September and currently has six additional depositions

Case 2:04-cv-00754-JAT

Document 59

Filed 09/20/2006

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scheduled (four of which are out of town) between the date of this motion and September 29, 2006. No previous extensions have been requested in connection with Defendant's motion for partial summary judgment. Respectfully submitted this 20th day of September, 2006. MARSHALL LAW GROUP, P.C. ___________s/Mishka L. Marshall____________________ Mishka L. Marshall 777 East Thomas Road, Suite 210 Phoenix, AZ 85014 Attorney for Plaintiff

_______________________ CERTIFICATE OF SERVICE I hereby certify that on September 20, 2006 I transmitted by electronic filing the foregoing Plaintiff's Motion for Extension of Time in Which to Respond to Defendant's Motion for Partial Summary Judgment.

s/Mishka L. Marshall Mishka L. Marshall _

Case 2:04-cv-00754-JAT

Document 59 - 2 Filed 09/20/2006

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