National Federation of the Blind, et al v. Arizona Board of Regents, et al

Filing 18

MOTION to Continue Time to Respond to Complaint and Motion for Preliminary Injunction by Arizona Board of Regents, Arizona State University. (Hudson, Lisa)

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1 TERRY GODDARD Attorney General 2 7 Lisa K. Hudson, 012597 Alisa Blandford, 022901 Assistant Attorney General 1275 W. Washington Phoenix, Arizona 85007-2997 Telephone: (602) 542-7673 Telephone: (602) 542-7687 Fax: (602) 542-7644 8 Attorneys for Defendant 3 4 5 6 9 IN THE UNITED STATES DISTRICT COURT 10 FOR THE DISTRICT OF ARIZONA 11 12 13 The NATIONAL FEDERATION OF THE BLIND, The AMERICAN COUNCIL OF THE BLIND, and DARRELL SHANDROW, 14 Plaintiff, 15 MOTION TO CONTINUE TIME TO RESPOND TO COMPLAINT AND MOTION FOR PRELIMINARY INJUNCTION vs. 16 Case No: CV09-01359 GMS The ARIZONA BOARD OF REGENTS and ARIZONA STATE UNIVERSITY, 17 Defendants. 18 (Assigned to Honorable G. Murray Snow) 19 20 Defendants, through counsel, respectfully move for an order extending the time to 21 respond to Plaintiffs’ Complaint and Motion for Preliminary Injunction from July 15, 22 2009 to July 24, 2009. This motion is made based on genuine need and not for purposes 23 of delay. Defendants’ counsel has spoken with Plaintiffs’ counsel, who has agreed to the 24 continuance. 25 MEMORANDUM OF POINTS AND AUTHORITIES 26 On June 25, 2009, Plaintiffs served their Complaint; Motion and Order for 27 28 Expedited Discovery; Motion and Order for Preliminary Injunction; as well as their 1 Request and Order for Pretrial Conference upon Defendants. Defendants began working 2 on their responses to these documents immediately upon receipt. 3 Notwithstanding Defendants’ efforts, a continuance of the July 15, 2009 deadline 4 is necessary due to the inaccessibility of certain of Defendants’ employees. Defendant 5 Arizona State University is currently out of session and many of its employees are 6 currently on vacation, will be leaving soon for vacation, or are otherwise inaccessible. 7 At lease some of these employees, including Defendant’s general counsel, are necessary 8 for a full and complete response to Plaintiffs’ filings. Defendants’ counsel has 9 determined that a short continuance will be sufficient to combat the scheduling issues, 10 allowing Defendants time to contact the necessary employees and gather relevant 11 documentation. 12 For the foregoing reasons, Defendants respectfully request that the deadline for 13 filing responses to Plaintiffs’ Complaint and Motion for Preliminary Injunction be 14 continued until July 24, 2009. 15 RESPECTFULLY submitted this 10th day of July, 2009. Terry Goddard Attorney General 16 17 s/ Lisa K. Hudson__________ Lisa K. Hudson Assistant Attorney General Attorney for Defendant 18 19 20 21 22 23 24 25 26 27 28 2 1 2 3 4 5 6 7 8 9 10 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 mailed a copy of same to any non-registrants, this this 10th day of July, 2009 to: Andrew S. Friedman Guy A. Hansen BONNETT, FAIRBOURN, FRIENDMAN & BALINT, P.C. 2901 North Central Avenue, Suite 1000 Phoenix, AZ 85012 Daniel F. Goldstein BROWN, GOLDSTEIN & LEVY, LLP 120 E. Baltimore St., Suite 1700 Baltimore, MD 21202 11 12 13 Amy Robertson FOX & ROBERTSON, P.C. 104 Broadway, Suite 400 Denver, CO 80203 15 Eve Hill 1667 K St. NW, Suite 640 Washington, DC 2006 16 Attorneys for Plaintiff 14 17 18 19 20 s/ Chris Austin Secretary to Lisa K. Hudson 506545 21 22 23 24 25 26 27 28 3

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