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

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PAUL K. CHARLTON United States Attorney District of Arizona SUZANNE M. CHYNOWETH Assistant U.S. Attorney Arizona State Bar No. 6835 Two Renaissance Square 40 North Central Avenue, Suite 1200 Phoenix, Arizona 85004-4408 Telephone: (602) 514-7500 Facsimile: (602) 514-7760 E-Mail: [email protected]

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA Alexander Jung, CIV-04-0429-PHX-MHM Plaintiff, v. John E. Potter, Postmaster General, Defendant. DEFENDANT'S REQUEST TO EXTEND TIME TO FILE HIS REPLY IN SUPPORT OF HIS MOTION FOR SUMMARY JUDGMENT (Second Request)

Defendant, Postmaster General John E. Potter, hereby requests that the Court extend the

15 deadline for filing his Reply in Support of His Motion for Summary Judgment by five hours, 16 until June 6, 2006 at 5:00 a.m. Good cause exists for this request because undersigned counsel 17 has been diligently working on this reply, including over the week-end and into the early hours 18 of the morning of June 6, 2006. Despite having worked at least twenty (20) hours over the 19 week-end on the two projects mentioned in the first request to extend the deadline for filing the 20 reply, undersigned counsel was unable to meet the requested extended deadline of June 5, 2006. 21 It is therefore requested that the Court enter an order extending the time for filing a reply

22 as requested. 23 24 25 26 27 28 Respectfully submitted this 6th day of June, 2006. PAUL K. CHARLTON United States Attorney District of Arizona s/Suzanne M. Chynoweth Suzanne M. Chynoweth Assistant U.S. Attorney

Case 2:04-cv-00429-MHM

Document 79

Filed 06/06/2006

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1 CERTIFICATE OF SERVICE 2 I hereby certify that on June 6, 2006, I electronically transmitted the attached document 3 to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of 4 Electronic Filing to the following CM/ECF registrants: 5 6 Rosval A. Patterson 777 E. Thomas Rd. 7 Phoenix, AZ 85014 8 S/ Suzanne M. Chynoweth 9 Office of the U.S. Attorney 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2

Case 2:04-cv-00429-MHM

Document 79

Filed 06/06/2006

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