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

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CHERI L. McCRACKEN

Cheri L. McCracken, Esq.
State Bar # 006111 2402 North 24th Street Phoenix AZ 85008-1804 (602) 231-0595 Attorney for Plaintiff

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Jose Castillo, Plaintiff, v. Gale A. Norton, Secretary, United States Department of the Interior, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) No. CIV'02 2043 PHX ROS MOTION TO EXTEND TIME TO RESPOND TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT (Second Request)

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2402 NORTH 24TH STREET PHOENIX, AZ 85008-1804 (602) 231-0595 (PHONE) (602) 231-0841 (FAX)

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COMES NOW the undersigned attorney for Plaintiff Jose Castillo ("Castillo"), and move this Court for an extension of time for Plaintiff to respond to Defendant's Motion for Summary Judgment. This is Plaintiff's second request. The response is presently due on September 8, 2005. Plaintiff moves for the extended date of September 30, 2005. Plaintiff's counsel spoke to the Defendant's counsel who has no objection. Defendant has made a settlement offer to Plaintiff which Ms. McCracken feels the need to discuss this with Plaintiff in person. Ms. McCracken's office has been trying to set up this appointment with Plaintiff. Due to Plaintiff's schedule, it can take a week or two for him to return calls and email to counsel. Defendants' reply will be due as set forth in Local Rule 1.10(l), 15 days after service of the response.

Case 2:02-cv-02043-DKD

Document 59

Filed 09/08/2005

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It is therefore respectfully requested that time for Plaintiff's response be extended until September 30, 2005. RESPECTFULLY SUBMITTED this 8th day of September, 2005 . Cheri L. McCracken, Esq.

s/ Cheri L. McCracken Cheri L. McCracken 2402 N. 24th Street Phoenix AZ 85008-1804 Attorney for Plaintiff Electronically filed this 8th day of September, 2005

s/ Fran Townsend

Case 2:02-cv-02043-DKD

Document 59

2 Filed 09/08/2005

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