Free Response in Opposition to Motion - District Court of Arizona - Arizona

John E. Karow, SBN 014200 LAWOFFICE JOHNE. KAROW OF 11350 North 104fhPlace Scottsdale, Arizona 85259 (480) 391-2236 Attorneys for Defendant IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA LINDA HINTON, an individual, Plaintiff, VS. PROGUARD SECURITY, an Arizona corporation, Defendant.
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No.

CIV 03-1985-PHX-SRB

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DEFENDANT'S RESPONSE TO IVOTICE AND MO1-ION FILED BY PLAINTIFF (Assigned to the Hon. Susan R. Bolton) (Oral Argument Requested)

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Defendant ProGuard Security ("Defendant") responds partly in support and partly in opposition to the July 25, 2005, "Notice to Court" filed by Plaintiff Linda Hinton ("Plaintiff') on the SI-~bjects the requests by the Plaintiff to extend the time for of discovery and the request by Defendant to extend the time for filing lblotions for Summary Judgment. Plaintiff, despite being represented bv competent counsel at the time the discovery deadline passed has asked the Court to extend the time for her to conduct additional discovery. Based on Plaintiff's request, Defendant previously asked the Court to extend the time to file lklotions for Summary Judgment to a reasonable time after Plaintiff completes any period for additional discovery granted by .the Court. Defendant objects to the granting of Plaintiff's request on the grounds of fairness since an extension of discovery allows Plaintiff the opportunity to identify new witnesses and information requiring further depositions and evaluation of evidence by

Case 2:03-cv-01985-SRB

Document 61

Filed 08/20/2005

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Defendant without allowing Defendant to make an appropriate response by motion. Defendant suggests that because Plaintiff is unrepresented an extension of both deadlines is reasonable in the interests of assuring that Plaintiff has the opportunity to present her case and that Defendant has the opportunity to fully defend itself RESPECTFULLY SUBMITTED, this 15thday of August, 2005.

North 104thPlace Arizona 85259 Attorney for Defendant Original filed this 15thday of August, 2005, with: Clerk of the District Court Sandra Day O'Connor U.S. Courthouse 401 West Washington Street Phoenix, AZ 85003 and, COPY HAND DELIVERED TO: Hon. Susan R. Bolton Judge of .the District Court Sandra Day O'Connor U.S. Courthouse 401 West Washington Street Phoenix, AZ 85003 and, COPY mailed this 15thday of August, 2005, to: Linda Hinton 2015 North 37thPlace Phoenix, AZ 850 Plaintiff pro per

Case 2:03-cv-01985-SRB

Document 61

Filed 08/20/2005

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