Motion Picture Association of America v. CrystalTech Web Hosting Inc.

Filing 417

Motion Picture Association of America v. CrystalTech Web Hosting Inc.

Doc. 417

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SURRANO LAW OFFICES
Attorneys at Law

3200 North Central Avenue, Suite 2500 Phoenix, Arizona 85012 Phone: [phone] Fax: [phone]

Charles J. Surrano III (007732) [e-mail] John N. Wilborn (013714) [e-mail] Trinette G. Kent (025180) [e-mail] Attorneys for Plaintiff UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA CINDY PADILLA, an Arizona resident, Plaintiff, vs. NORTHWESTERN MUTUAL LIFE INSURANCE CO., a foreign insurer, Defendant. The Parties hereby agree that good cause exists for this Court to enter an order allowing the Plaintiff leave to file a response to the Defendant's Cross Motion for Summary Judgment and allow the Defendant to file a reply thereto because the Defendant filed the motion before it had leave to file, leaving the briefing of a response in a legal purgatory. The Court has granted the right to file the cross motion as of September 15, 2009. Good cause exists to allow the Plaintiff to file a response to the cross motion for summary judgment because the Plaintiff was waiting for the Court to decide the Defendant's motion. The Parties request that this Court grant leave on an 1
Dockets.Justia.com

Case No.: CV-08-875-PHX-SRB STIPULATION FOR LEAVE TO FILE RESPONSE AND REPLY TO THE DEFENDANT'S CROSS MOTION FOR SUMMARY JUDGMENT RE: BREACH OF CONTRACT

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accelerated basis so that the parties can finalize briefing and stay within this Court's Scheduling Order. The Plaintiff agrees to file her response by October 1, 2009 and the Defendant will file its reply by October 16, 2009. Respectfully submitted on September 17, 2009. SURRANO LAW OFFICES By: s/John N. Wilborn Charles J. Surrano, III John N. Wilborn Trinette G. Kent 3200 N. Central Avenue, Suite 2500 Phoenix, AZ 85012 Attorneys for Plaintiff

LEWIS & ROCA By: s/Jon Weiss, with permission Jon Weiss 40 North Central Avenue Phoenix, Arizona Attorneys for Defendant

CERTIFICATE OF SERVICE I hereby certify that on September 17, 2009, I electronically transmitted the attached documents to the Clerk's Office using the CM/ECF System for filing.

s/Kim M. Hearn

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