Free Objection - District Court of Arizona - Arizona

1 2 3 4

EDWARD D. FITZHUGH P.O. Box 24238 Tempe, Arizona 85285-4238 (480) 752-2200 Bar No. 007138 Attorney for Plaintiffs IN THE UNITED STATES DISTRICT COURT

5
FOR THE DISTRICT OF ARIZONA

6 7 8 9 10
vs. Joe Ramirez and Ana Ramirez, Individually and as Parents and Legal Guardians of Jose Ramirez; Plaintiffs, ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. CIV03-0060 PHX-ROS OBJECTION TO DEFENDANTS' AMENDED STATEMENT OF COSTS

11 12 13 14 15
Glendale Union High School District No. 205; John Doe and Jane Doe I-X; ABC Corporations I-X; and XYZ Partnerships I-X, Defendants.

(Assigned to the Honorable Roslyn O. Silver)

COME NOW Plaintiffs and object to Defendants' Amended Statement of Costs and

16
Notice of Taxation of Costs.

17
There is no final judgment in this matter. Plaintiffs filed two separate causes of

18
action. First, a cause of action for failure to protect Plaintiff; and then, second, a separate

19
and distinct cause of action regarding the failure of Plaintiff's teachers, who learned of the

20
assault, to report it to the proper authorities. These actions were consolidated.

21
The second cause of action, Ramirez II, is on-going, and the costs listed by

22
Defendants in their Amended Statement of Costs are overlapping costs with Ramirez II.

23
WHEREFORE, Plaintiff respectfully requests the Court await the final judgment on

24
this matter before any award of costs.

25
RESPECTFULLY SUBMITTED this 20th day of December, 2006.

26 27 28
Case 2:03-cv-00060-ROS
/s/ Edward D. Fitzhugh Edward D. Fitzhugh Attorney for Plaintiffs

Document 145

Filed 12/20/2006

Page 1 of 2

1 2 3 4 5 6 7 8

I hereby certify that on December 20, 2006, I electronically transmitted the foregoing 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: J. Steven Sparks, Esq. Sanders & Parks, P.C. 3030 N. Third Street, Ste. 1300 Phoenix, Arizona 85012-3099 Attorneys for Defendants ___/s/S.J. Odneal____

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2
Case 2:03-cv-00060-ROS Document 145 Filed 12/20/2006 Page 2 of 2