United States of America v. Arizona, State of, et al

Filing 155

Consent MOTION for Extension of Time to File Response/Reply to Counterdefendants' Motion to Dismiss Counterclaims and Exceed Page Limits by Arizona, State of, Janice K Brewer. (Attachments: # 1 Text of Proposed Order)(Hiller, Evan)

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Thomas C. Horne (#002951)
Attorney General
Michael Tryon (#003109)
Evan Hiller (#028214)
Assistant Attorneys General
1275 West Washington Street
Phoenix, Arizona 85007-2926
Telephone: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendant/
Counterclaimant the State of Arizona

John J. Bouma (#001358)
Robert A. Henry (#015104)
Joseph G. Adams (#018210)
Kelly A. Kszywienski (#025578)
SNELL & WILMER L.L.P.
One Arizona Center
400 E. Van Buren
Phoenix, AZ 85004-2202
Telephone: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants/Counterclaimants

Joseph A. Kanefield (#015838)
Office of Governor Janice K. Brewer
1700 W. Washington, 9th Floor
Phoenix, AZ 85007
Telephone: [phone]
[e-mail]
Attorney for Defendants/Counterclaimants
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF ARIZONA
The United States of America,
Plaintiff,
v.
The State of Arizona; and Janice K. Brewer,
Governor of the State of Arizona, in her
Official Capacity,
Defendants.

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The State of Arizona; and Janice K. Brewer,
Governor of the State of Arizona, in her
Official Capacity,
Counterclaimants,
v.
The United States of America; the United
States Department of Homeland Security;
Janet Napolitano, Secretary of the United
States Department of Homeland Security, in
her official capacity; the United States
Department of Justice; and Eric H. Holder,
Jr., Attorney General for the United States
Department of Justice, in his official capacity,
Counterdefendants.

No. 2:10-cv-01413-SRB
CONSENT MOTION TO
EXTEND DEADLINES AND
EXCEED PAGE LIMITS FOR
COUNTERCLAIMANTS’
RESPONSE TO
COUNTERDEFENDANTS’
MOTION TO DISMISS
COUNTERCLAIMS AND FOR
COUNTERDEFENDANTS’
REPLY THERETO

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Counterclaimants, the State of Arizona (“Arizona”) and Governor Janice K.

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Brewer (“Brewer”), respectfully request leave to exceed the page limit set forth in L.R.Civ

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7.2(e) for their Response to Counterdefendants’ Motion to Dismiss. In light of the range

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and magnitude of issues raised in this matter, Counterdefendants requested and received

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leave to exceed the page limits for their Motion to Dismiss and Supporting Memorandum.

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Counterclaimants must address a similar range of issues in their response to

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Counterdefendant’s motion and therefore seek leave to file a Response, including

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Supporting Memorandum, which does not exceed 32 pages in length, after which

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Counterdefendants may file a Reply that does not exceed 20 pages.

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Counterclaimants further request that this Honorable Court order the following
deadlines:

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• Counterclaimants shall file their Response on or before May 31, 2011.

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• Counterdefendants shall file their Reply thereto on or before June 22, 2011.

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Counsel for Counterdefendants have been contacted and have consented to the

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relief sought herein.
DATED this 15th day of April, 2011.

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By s/Evan Hiller
Thomas C. Horne
Attorney General
Michael Tryon
Evan Hiller
Assistant Attorneys General
1275 West Washington Street
Phoenix, Arizona 85007-2926
Attorneys for the State of Arizona

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1708857v3

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By s/Joseph A. Kanefield with permission
Joseph A. Kanefield
Office of Governor Janice K. Brewer
1700 W. Washington, 9th Floor
Phoenix, AZ 85007

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and

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SNELL & WILMER L.L.P.

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By s/Robert A. Henry with permission
John J. Bouma
Robert A. Henry
Joseph G. Adams
Kelly A. Kszywienski
One Arizona Center
400 E. Van Buren
Phoenix, AZ 85004-2202
Attorneys for the State of Arizona and Janice K.
Brewer, Governor of the State of Arizona

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CERTIFICATE OF SERVICE

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I hereby certify that on April 15th , 2011, I electronically transmitted the foregoing

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document to the Clerk’s Office using the CM/ECF System for filing and transmittal of a

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Notice of Electronic Filing to the CM/ECF registrants on record, including:

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Tony West
Dennis K. Burke
Arthur R. Goldberg
Varu Chilakamarri
Joshua Wilkenfeld
U.S. Department of Justice, Civil Division
20 Massachusetts Avenue, N.W.
Washington, D.C. 20530

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s/Evan Hiller

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1708857v3

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