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

Filing 64

NOTICE re Plaintiff's Notice of Intent to File a Motion for Leave to Amend Complaint by Arizona, State of . (Ray, Kevin)

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1 2 3 THOMAS C. HORNE Attorney General Firm Bar No. 14000 8 Kevin D. Ray, No. 007485 Aubrey Joy Corcoran, No. 025423 Assistant Attorneys General 1275 West Washington Street Phoenix, Arizona 85007-2926 Telephone: (602) 542-8328 Facsimile: (602) 364-0700 Email: 9 Attorneys for Plaintiffs 4 5 6 7 10 IN THE UNITED STATES DISTRICT COURT 11 FOR THE DISTRICT OF ARIZONA 12 13 STATE OF ARIZONA, et al., 14 Plaintiffs, 15 vs. 16 UNITED STATES OF AMERICA, et al., 17 18 19 20 21 22 23 24 25 26 27 Defendants. Case No. 11-CV-01072-PHX-SRB PLAINTIFFS’ NOTICE OF INTENT TO FILE A MOTION FOR LEAVE TO AMEND COMPLAINT (Honorable Susan R. Bolton) The Plaintiffs, State of Arizona; Janice K. Brewer, Governor of the State of Arizona, in her Official Capacity; Will Humble, Director of Arizona Department of Health Services, in his Official Capacity; and Robert C. Halliday, Director of Arizona Department of Public Safety, in his Official Capacity (collectively “Plaintiffs”), hereby give notice to the Court and other parties of their intent to file a Motion for Leave to Amend their Complaint. Pursuant to the Court’s request during oral argument, and Federal Rule of Civil Procedure 15(a)(2), Plaintiffs will be seeking to amend their Complaint to refine their position 1 and resolve any case or controversy issues. Due to the intervening holidays and other staff and 2 scheduling issues, Plaintiffs advise the Court and the other parties that they will be filing their 3 Motion for Leave to Amend Complaint on or before Monday, January 9, 2011. 4 Plaintiffs respectfully request that the Court withhold any ruling on the pending 5 Motions to Dismiss until the Court has considered the Plaintiffs’ future filings and the 6 December 14, 2011 filings of prospective Plaintiff-Intervenors Maricopa County and Joy Rich. 7 8 9 10 11 12 13 14 DATED this 16th day of December, 2011. THOMAS C. HORNE Attorney General s/Kevin Ray Kevin D. Ray Aubrey Joy Corcoran Assistant Attorneys General Attorneys for Plaintiffs 15 16 17 18 19 20 21 22 23 24 25 26 27 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CERTIFICATE OF SERVICE 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 16th day of December, 2011 to: Scott Risner, Esq. U.S. Department of Justice Civil Division, Federal Programs Branch 20 Massachusetts Ave., N.W. Washington, D.C. 20001 Brian Bergin, Esq. Rose Law Group 6613 N. Scottsdale Road, Suite 200 Scottsdale, AZ 85250 Lisa T. Hauser, Esq. Gammage & Burnham Two North Central, 15th Floor Phoenix, AZ 85004 Thomas W. Dean, Esq. Thomas W. Dean Esq. PLC 323 N Leroux Street, Suite 101 Flagstaff, AZ 86001 Ezekiel R. Edwards, Esq. American Civil Liberties Union 1101 Pacific Avenue, Suite 333 Santa Cruz, CA 95060 Thomas P. Liddy, Esq. Maricopa County Attorney’s Office 222 North Central Avenue, Suite 1100 Phoenix, AZ 85004 By: /s/ Lisa Danczewski #2543223 26 27 3

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