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

1 JACOB S—SCI·IWARTZ LAW OFFICE
Loretta jacobs-Schwartz I ·
2 8687 East Via de Ventura, Suite 306
Scottsdale, Arizona 85258
3 Telephone: (480) 367-8697 i
Facsimile: (480) 367-8699 Y
4 E-mail: loretta@lorettajschwartzcom _
SBN 006900 2
5 Y
UNITED STATES DISTRICT COURT
DISTRICT OF ARIZONA
9 _ _ _ Case No.: CIV-02-00913-PHX-SMM
STUART MARUCE, an individual,
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Plaintiff,
11 UNOPPOSED MOTION FOR j?
VS- 30-DAY EXTENSION TO FILE
12 PLAINTIFF 'S RESPONSE TO
PHELPS DODGE CORPORATION, a DEFENDANTS RENEW/ED s
13 _ MOTION FOR ATTORNEYS' FEES
New York Corporation,
14 1
Defendant
15 1
Plaintiff, by and through counsel undersigned, hereby moves this Honorable Court
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for an extension of time of thirty (30) days, until November 16, 2007, in which to Respond
17 is
to Defendant’s Renewed Motion for Attorneys’ Fees.
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The reason for this request is that Plaintiff’s counsel has been seriously ill for several
months and has just recently been able to retum to work on a part-time basis. For this
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reason, counsel now faces deadlines that were extended (Motion for Summaryjudgment and
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a 4-Day Hearing) in another matter, because of her poor health.
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Plaintiff’s counsel has discussed this issue with Defendant’s counsel, Ronald Stolkin,
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and counsel has no objection. The parties have also mutually agreed to enter into settlement
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discussions regarding said attorneys’ fees.
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Case 2:02-cv—00913—SI\/II\/I Document 119 Filed 10/10/2007 Page 1 of 2

1 Plaintiff hereby respectfully requests this Honorable Court grant him an extension,
2 until November 16, 2007,111 which to file his Response. A
3 s
4 RESPECT FULLY SUBMITTED this @1 day of October, 2007.
I
By: s/ Loretta [acobs-Schwartz p
7 Loretta jacobs-Schwartz, Esq. I
8 8687 E. Via de Ventura, Suite 306
Scottsdale, AZ 85258
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10
“
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I hereby certify that on this 10th day of October, 2007, I electronically transmitted the
13 attached document to the Clerk’s office using the ECP Systems for filing and transmittal of a
Notice of Electronic Filing and a copy was delivered via U.S. Mail to:
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15 Ronald Stolkin
Michelle Tyler
16 FENNEMORE CRAIG
3003 N. Central Avenue, Suite 2600
17 Phoenix, AZ 85012-2913
Attorneys for Defendant
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19 A courtesy COPY was provided on the same date to:
20 The Honorable Stephen M. McNamee
United States District Court
21 401 West \Y/ashington Street, SPC 60
22 Phoenix, AZ 85003-2158
By: s/Michele L. Glendenning
24 Michele L. Glendenning, Paralegal
Case 2:02-cv—OO913—SI\/II\/I Document 119 Filed 10/10/2007 Page 2 of 2

Case 2:02-cv-00913-SMM

Document 119

Filed 10/10/2007

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Case 2:02-cv-00913-SMM

Document 119

Filed 10/10/2007

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