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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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: [phone]
Telephone: [phone]
Fax: [phone]
[e-mail]
[e-mail]

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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
506545

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