Strojnik v. Costar Realty Information, Inc. et al

Filing 375

Strojnik v. Costar Realty Information, Inc. et al

Doc. 375

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David J Adamski, Esq. (020334) [e-mail] BETHUNE & ASSOCIATES 14435 North 7th Street, Suite 201 Phoenix, AZ 85022 [phone] Attorneys for Plaintiff

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA CON-WAY FREIGHT, INC., a Delaware Corporation, Plaintiff, vs. AMBATH, LLC, a Delaware Limited Liability Company dba AMBATH REBATH, DOE CORPORATION 1-10, JOHN DOES 1-10; Defendants. AMBATH, LLC, a Delaware Limited Liability Company dba AMBATH REBATH, Third-Party Plaintiff, v. GLOBALTRANZ ENTERPRISES, LLC, an Arizona limited liability company; DOES 1 through 10, Third-Party Defendants. GLOBALTRANZ ENTERPRISES, LLC, an Arizona limited liability company, Third-Party Counterclaimant, v. NO. CV 09-1669-PHX-NVW STIPULATION TO CONTINUE THE SCHEDULING CONFERENCE SET FOR NOVEMBER 13, 2009 at 9:00 a.m. AND SCHEDULING ORDER DEADLINES REFERENCING THAT DATE (First Request)

21 22 23 AMBATH, LLC, a Delaware Limited Liability Company dba AMBATH REBATH, Third-Party Counterdefendant.
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Dockets.Justia.com

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The parties to this action having made formal appearances, CON-WAY TRANSPORTATION SERVICES, INC., AMBATH, LLC and GLOBALTRANZ ENTERPRISES, LLC, by and through their undersigned counsel, hereby stipulate to continue the scheduling conference currently set for November 13, 2009 at 9:00 a.m. and the scheduling order deadlines referencing that date. No Doe parties have been served or made appearances in this matter thus far. Subsequent to the Scheduling Order, filed by the Court on September 9, 2009, there was file a Third Party Complaint, and Answer to that Third Party Complaint and a Counterclaim against the Third Party Plaintiff. The Pleading stage of this litigation remains active as the time for responding to the Third Party Counterclaim remains open and no such response has to date been filed. Given the active stage of the initial pleadings, the matter is not at a point where initial disclosures, discovery requests or even formal discovery plans would be appropriate. As such, the parties hereto jointly request that the scheduling conference set for November 13, 2009 at 9:00 a.m. be continued for approximately sixty (60) days. Additionally, the parties hereto request that the deadlines detailed in the Court's September 9, 2009 Scheduling Order that reference that scheduling conference date be continued as well. This Stipulation to Continue is made in the interests of justice and not merely for the purpose of delay. \\ \\ \\
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RESPECTFULLY SUBMITTED this 29th day of October, 2009.

BETHUNE & ASSOCIATES 3 4 5 6 BAUMANN, DOYLE, PAYTAS & BERNSTEIN, P.A. 7 8 9 10 STINSON MORRISON HECKER LLP 11 12 13 14 15 16 17 18 19 20 21 22 23 CERTIFICATE OF SERVICE I hereby certify that on October 29, 2009 I electronically transmitted the attached 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: Ambath, LLC GlobalTranz Enterprises, LLC I hereby certify that on _______, I served the attached document by US MAIL on the following, who are not registered participants of the CM/ECF System in this action: N/A _/s/ David J Adamski_ By _/s/ James E. Holland, Jr., with permission_ James E. Holland, Jr. (021826) Attorneys for GlobalTranz Enterprises, LLC By _/s/ Gary T. Doyle, with permission_ Gary T. Doyle (015033) Attorneys for Defendant Ambath, LLC By_/s/ David J Adamski___________ David J Adamski (020334) Attorneys for Con-Way Freight, Inc.

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