Cygnus Systems, Inc. v. Microsoft Corporation, et al

Filing 747

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Cygnus Systems, Inc. v. Microsoft Corporation, et al Doc. 747 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 RICHARD M. MARTINEZ, SBA No. 7763 312 South Convent Tucson, Arizona 85701 (520) 327-4797 phone (520) 320-9090 fax Counsel for Plaintiff UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA MARIA P. PADILLA, ) ) Plaintiff, ) ) ) v. ) ) ) STATE OF ARIZONA, dba ) Arizona Department of Corrections; ) Antonio Villa and "Jane Doe Villa, ) Husband & Wife, ) ) Defendants. ) ) CV 06-3007 PHX JAT MOTION TO ENLARGEMENT OF TIME TO COMPLETE DISCOVERY AND RELATED` DEADLINES Counsel for plaintiff, Maria P. Padilla, hereby seeks on her behalf an enlargement of time to complete discovery and related deadlines. The current discovery deadline is January 18, 2008. Sixty (60) additional days are requested. This additional time is needed due to the mental status of plaintiff, who is on an extended medical leave from work and under the active care of a psychologist, James Parker, at Yuma Bio-Behavioral Clinical Psychology, PLLC. Dr. Parker has confirmed that Ms. Padilla is under his care and has not been able to work since July 10, 2007. She currently suffers from panic disorder, major depression, moderate and poor concentration to the degree that she cannot work. Medications have been prescribed and are part of the treatment plan. Ms. Padilla's condition is related to the work environment and the consistent pattern of hostility she has been confronted with since reporting her Sargent, Villa, for sexual harassment. For example on June 12, 2007 Ms. Padilla 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 was served with an official departmental notice that she was terminated. This action was then rescinded and upon returning to work on June 15th she was shortly thereafter confronted with new allegations of misconduct on July 9, 2007. Ms. Padilla's deposition was scheduled for September 10, 2007. This date was agreed to by counsel. Since then Dr. Parker has advised counsel that Ms. Padilla would not be able to attend a deposition before the middle of October. Counsel is starting a trial on October 16, 2007 in Alvarado v. Cajun Operating Company, CV 04-631 TUC CKJ. This jury trial is expected to last up to two weeks. Thus counsel and Ms. Padilla would not be available until the week of November 5th for her deposition. This request is in compliance with the applicable Federal Rules of Civil Procedure and the Local Rules for the District of Arizona. Good cause exist for granting the short extension requested. Respectfully submitted this 15th day of August, 2007. s/Richard M. Martinez, Esq. RICHARD M. MARTINEZ, ESQ. Counsel for Plaintiff I certify that 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, if CM/ECF registrants, and mailedtha copy of same to any non-registrants, this 15 day of August, 2007: Rebecca J Herbst, Assistant Attorney General Office of the Attorney General State of Arizona 1275 West Washington Phoenix, Arizona 85007-2926 Attorney for Defendant State of Arizona Brian Kaven, Esq. BURCH & CRACCHIOLO 702 East Osborn, Suite 200 Phoenix, Arizona 85011-6882 Attorney for Defendants' Villa s/Richard M. Martinez, Esq. -2-

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