National Federation of the Blind, et al v. Arizona Board of Regents, et al
Filing
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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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TERRY GODDARD
Attorney General
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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
Lisa.Hudson@azag.gov
Alisa.Blandford@azag.gov
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Attorneys for Defendant
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IN THE UNITED STATES DISTRICT COURT
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FOR THE DISTRICT OF ARIZONA
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The NATIONAL FEDERATION OF
THE BLIND, The AMERICAN
COUNCIL OF THE BLIND, and
DARRELL SHANDROW,
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Plaintiff,
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MOTION TO CONTINUE TIME TO
RESPOND TO COMPLAINT AND
MOTION FOR PRELIMINARY
INJUNCTION
vs.
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Case No: CV09-01359 GMS
The ARIZONA BOARD OF REGENTS
and ARIZONA STATE UNIVERSITY,
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Defendants.
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(Assigned to Honorable G. Murray Snow)
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Defendants, through counsel, respectfully move for an order extending the time to
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respond to Plaintiffs’ Complaint and Motion for Preliminary Injunction from July 15,
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2009 to July 24, 2009. This motion is made based on genuine need and not for purposes
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of delay. Defendants’ counsel has spoken with Plaintiffs’ counsel, who has agreed to the
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continuance.
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MEMORANDUM OF POINTS AND AUTHORITIES
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On June 25, 2009, Plaintiffs served their Complaint; Motion and Order for
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Expedited Discovery; Motion and Order for Preliminary Injunction; as well as their
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Request and Order for Pretrial Conference upon Defendants. Defendants began working
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on their responses to these documents immediately upon receipt.
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Notwithstanding Defendants’ efforts, a continuance of the July 15, 2009 deadline
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is necessary due to the inaccessibility of certain of Defendants’ employees. Defendant
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Arizona State University is currently out of session and many of its employees are
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currently on vacation, will be leaving soon for vacation, or are otherwise inaccessible.
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At lease some of these employees, including Defendant’s general counsel, are necessary
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for a full and complete response to Plaintiffs’ filings. Defendants’ counsel has
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determined that a short continuance will be sufficient to combat the scheduling issues,
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allowing Defendants time to contact the necessary employees and gather relevant
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documentation.
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For the foregoing reasons, Defendants respectfully request that the deadline for
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filing responses to Plaintiffs’ Complaint and Motion for Preliminary Injunction be
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continued until July 24, 2009.
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RESPECTFULLY submitted this 10th day of July, 2009.
Terry Goddard
Attorney General
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s/ Lisa K. Hudson__________
Lisa K. Hudson
Assistant Attorney General
Attorney for Defendant
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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
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Amy Robertson
FOX & ROBERTSON, P.C.
104 Broadway, Suite 400
Denver, CO 80203
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Eve Hill
1667 K St. NW, Suite 640
Washington, DC 2006
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Attorneys for Plaintiff
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s/ Chris Austin
Secretary to Lisa K. Hudson
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