Free Motion to Stay - District Court of Arizona - Arizona


File Size: 76.3 kB
Pages: 3
Date: September 22, 2006
File Format: PDF
State: Arizona
Category: District Court of Arizona
Author: unknown
Word Count: 694 Words, 4,341 Characters
Page Size: 622.08 x 792 pts
URL

https://www.findforms.com/pdf_files/azd/34884/198.pdf

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San Francisco, CA 94110 1By________*__E_DEPUTY
e-mail: [email protected]
UNITED STATES DISTRICT COURT
IN AND FOR THE STATE OF ARIZONA
PHOENIX DIVISION
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CARLOS Arthur POWELL * n.c.case No. # CVO3—l8T9~PHX(JAT)
Plaintiff: E Honorable Judge J.A.TEILBORG,
_VS- Je
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C·MILES· ET AL- I Q. r>1,.A1u1·1FF"s NOTICE or calmer: OF
* ADDRESS AND MOTION FOR STAY TO
Rg5pOnd@nt5_ * SUBMIT ADDITIONAL EVIDENCE.
________,___,__d___________,__,_j
COMES NOW the Plaintiff Carlos Arthur Powell, in propia
persona, and respectfully submits his timely notice to the Court of
an address change as of September 6th, 2006. The plaintiff is no long-
er in custody, and is no longer at Victorville Federal Institution
located at P.O. Box # 5300, Adelanto, CA 92301-5300.
Plaintiff's new location and addresses are as follows:
Charles Powell, c/o Ken R. Peterson,esq. 2001 Mission St., P.OiBox #31B
San Francisco, CA 94110:e-mail: [email protected],or
[email protected]. The above is a paralegal firm that is in
fact assisting the litigation of this case.
MOTION FOR STAY:
Plaintiff now requests that the Honorable Court grant a
stay of proceedings for approximately (30) days to allow the plain-
Case 2:0 - - - -
R 3 cv 01819 JAT Document 198 (1 Fyled 09/22/2006 Page 1 of 3

tiff ample time to settle, and contact the proper individuals so
that the plaintiff will have support of the allegations before the
tribunal.
DEf&Hd&HtS have not been contacted as yet, because the
plaintiff had anticipated that the Court would have responded to the
pending motions prior to his release. The acts which were done to
this plaintiff are such that the plaintiff anticipates filing crim-
inal action against Mr. Scalet for filing erroneous and fraudulent
entries into federal file(s).
The extension/stay, would not in any way prejudice the de-
fendants in this case, and such a stay would allow the plaintiff the
course of justice which during his incarceration he was denied by the
defendants and had experienced reprisal for exercising those rights
to include that Scalet created and caused the deportation of the said
plaintiff.
WHEREFORE, the plaintiff moves for the following action by
this Tribunal:
1.) That the Court take Judicial Notice of the new
address change, and make that change in the files and,
2 2.} That the Court grant a (30) day stay of action
to allow the plaintiff the leeway of arranging and coming to aware-
T ness of the recent release, secure housing, and employment, etc.,as to
grant such an extremely short period, would not hinder the defendants
nor their counsels, and any other relief the Court finds fit to grant
under the circumstances of this case.
Dated this day of 2006.
Respectfully submitted;
l
Case 2:03-cv-01819-JAT Document 198 Fil Charles Ph Pcwallr
(2-] ed O9/22/2006 Page20f3

PROOF OF SERVICE:
l I HEREBY certify that a true and correct copy of the fore-
going has been furnished by U.S. Mail, pre-paid postage, to the below
parties of this case, this day of 2006,
Timothy Bojanoski, esquire
Attorney at Law
2901 Central Avenue suite # 800
Phoenix, Arizona
[and]
U.S. Assistant District Attorney
Phoenix Division Civil
c/o Sandra Day O'Connor Courthouse
U.S. District Court
Phoenix, Arizona
U.S. Department of Justice Counsel
For Homeland Security Division of I.C.E.
c/0 U.S.Department of Homeland Security
. Federal Building, (Central Avenue)
Phoenix, Arizona /
fl ,.
___A£/Pl4 £¥ /
arles Powe l
( 3 · I
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