Escobar v. Brewer et al

Filing 13

First MOTION for Leave to File Excess Pages for Memorandum of Points & Authorities Supporting Motion for Preliminary Injunction by Martin H Escobar. (Attachments: # 1 Text of Proposed Order)(Martinez, Richard)

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RICHARD M. MARTINEZ, SBA No. 7763 307 South Convent Avenue Tucson, Arizona 85701 [phone] phone [phone] fax [e-mail] Stephen Montoya, SBA No. 11791 Augustine B. Jimenez III, SBA No. 12208 Montoya Jimenez, P.A. The Great American Tower 3200 North Central Avenue, Suite 2550 Phoenix, Arizona 85012 [phone] [phone] (fax) [e-mail] [e-mail] Counsel for Plaintiff IN THE UNITED STATES DISTRICT COURT FOR THE STATE OF ARIZONA MARTIN H. ESCOBAR Plaintiff, v. JAN BREWER, Governor of the State of Arizona, in her Official and Individual Capacity, the City of Tucson, a municipal corporation, and Barbara LaWall, County Attorney, Pima County, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. CV 10-249 TUC DCB REQUEST TO EXCEED PAGE LIMITATION IN MEMORANDUM OF POINTS AND AUTHORITIES TO MOTION FOR PRELIMINARY INJUNCTION

Pursuant to LRCiv 7.2.(e), Plaintiff hereby request permission to exceed the 17 page limitation set forth in the instant local rule by filing a memorandum of points and authorities in support of his Motion for Preliminary Injunction that contains up to 35 pages (excluding exhibits). This request is made in order to provide Plaintiff with the opportunity to set forth in detail the law and facts supporting his request for a preliminary injunction. The

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applicable law and the material facts are complex and require a detailed explanation. Additionally, the preliminary equitable relief sought in the memorandum is critical to protecting the interests of local law enforcement officers, all Latinos citizens, residents, and guests of Arizona, and all persons present within the State of Arizona as of the effective date of the "Support Our Law Enforcement and Safe Neighborhoods Act," Senate Bill 1070, as amended by House Bill 2162, which is July 29, 2010. Plaintiff's request is reasonable, appropriate and will not prejudice the interests of any responding party. For the reasons noted, Plaintiff respectfully requests the Court for leave to exceed the page limitation set forth in the Local Rules and submit a memorandum of points and authorities up to 35 pages in length. Respectfully submitted this 31st day of May 2010. s/Richard M. Martinez, Esq. RICHARD M. MARTINEZ, ESQ. Stephen Montoya Augustine B. Jimenez III MONTOYA JIMENEZ, P.A. The Great American Tower 3200 North Central Avenue, Suite 2550 Phoenix, Arizona 85012 Counsel for Plaintiffs

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Copy electronically transmitted this 31st day of May 2010 via the USDC Clerk of Court using the CM/ECF System for filing and transmittal to: Michael Rankin, City Attorney City of tucson Michael W.L. McCory Principal Assistant City Attorney P.O. Box 2710 Tucson, Arizona 85726-7210 Attorneys for the City of Tucson John J. Bouma Robert A. Henry Joseph G. Adams SNELL & WILLMER, LLC One Arizona Center 400 East Van Buren Phoenix, Arizona 85004-2202 Joseph A. Kanfield Office of Governor Janice th Brewer K. 1700 West Washington, 9 Floor Phoenix, Arizona 85007 Attorneys for Defendant Governor Janice K. Brewer COPY sof the foregoing e-mailed this 31 t day of May 2010 to: Barbara LaWall County Attorney-Pima County 200 West Washington Tucson, Arizona 85701 Defendant s/Richard M. Martinez, Esq.

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