Free Stipulation - District Court of Arizona - Arizona

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LAW OFFICES One Arizona Center, 400 E. Van Buren Phoenix, Arizona 85004-2202 (602) 382-6000

David E. Rauch (#015261) Adam E. Lang (#022545) SNELL & WILMER L.L.P. One Arizona Center 400 E. Van Buren Phoenix, Arizona 85004-2202 Telephone: (602) 382-6522 Fax: (602) 382-6070 [email protected] [email protected] Attorneys for Plaintiff Anthony Keith Ogle IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA ANTHONY KEITH OGLE, No. CV03-200-PHX-NVW (MHB) Plaintiff, v. TERRY STEWART, Defendant. The parties stipulate and agree that Plaintiff may have additional time from THIRD JOINT STIPULATED REQUEST FOR EXTENSION OF TIME FOR PLAINTIFF TO FILE AMENDED COMPLAINT

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September 21, 2007, to and including November 21, 2007, in which to file his amended 15 complaint. Good cause supports this request. 16 The parties have worked diligently together in an attempt to amicably resolve this 17 matter. Both parties believe that they are on the verge of settlement and that, for the most 18 part, they have agreed to key settlement terms. But it has taken a good deal of time to get 19 documents and terms reviewed and approved by Plaintiff since he is still incarcerated, and 20 Plaintiff and his counsel have to go through the necessary procedures and steps before 21 they can correspond with one another. This can take several days at a time. Further, 22 Plaintiff's counsel is working with third parties in an attempt to resolve any outstanding 23 restitution Plaintiff still owes them as a result of his criminal sentence. That task has 24 taken a good amount of time, both in ascertaining, and then negotiating with, the 25 appropriate restitution beneficiaries. 26 The parties recognize that this is the third request to extend time for Plaintiff to 27 file his amended complaint. But they and their counsel believe such an extension will 28
Case 2:03-cv-00200-NVW-MHB Document 74 Filed 09/13/2007 Page 1 of 3

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LAW OFFICES One Arizona Center, 400 E. Van Buren Phoenix, Arizona 85004-2202 (602) 382-6000

benefit all parties involved and the Court as it will provide ample time to hopefully finalize an amicable resolution to this matter. Accordingly, the parties respectfully ask this Court to give Plaintiff until and including November 21, 2007, to file an amended complaint. The parties to this lawsuit are hopeful that this matter will be settled long before that date. A proposed order accompanies this Stipulation. DATED this 13th day of September, 2007. SNELL & WILMER L.L.P. By s/ Adam E. Lang David E. Rauch (#015261) Adam E. Lang (#022545) One Arizona Center 400 E. Van Buren Phoenix, Arizona 85004-2202 Telephone: (602) 382-6522 Fax: (602) 382-6070 [email protected] [email protected] Attorneys for Plaintiff Anthony Keith Ogle ARIZONA ATTORNEY GENERAL'S OFFICE By s/ Bruce L. Skolnik Terry Goddard Attorney General Bruce L. Skolnik (#009848) Assistant Attorney General 177 North Church Suite 1105 Tucson, Arizona 85701-1128 Telephone: (520) 388-7124 Fax: (520) 628-6050 [email protected] Attorneys for Defendant Terry Stewart

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Snell & Wilmer L.L.P.

2 Document -74 -

Filed 09/13/2007

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LAW OFFICES One Arizona Center, 400 E. Van Buren Phoenix, Arizona 85004-2202 (602) 382-6000

CERTIFICATE OF SERVICE I hereby certify that on September 13, 2007, I electronically transmitted the foregoing document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: Bruce L. Skolnik, Esq. ARIZONA ATTORNEY GENERAL'S OFFICE Assistant Attorney General 177 North Church Suite 1105 Tucson, Arizona 85701-1128 Attorneys for Defendant Terry Stewart s/ Adam E. Lang
2045831.1

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Case 2:03-cv-00200-NVW-MHB 3 Document -74 Filed 09/13/2007 Page 3 of 3

Snell & Wilmer L.L.P.