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Kelly_MatthewThe scheduling issues in this case clearly are the result of (Kelly’s) lack of familiarity with the mechanics of the new scheduling rules and the virtual gutting of Rule 38.1, Ariz. R. Civ. P.
For example, had Plaintiff timely propounded discovery on May 29, 2015, as permitted by the scheduling order, the responses would not have even been due until July 13, 2015, leaving a little more than two weeks to satisfy Rules 26(g) and 37(a)(2)(C), Ariz. R. Civ. P., then file a motion to compel if efforts to obtain the discovery were unsuccessful, in order to meet the discovery cutoff date. The scheduling issues in this case clearly are the result of lack of familiarity with the mechanics of the new scheduling rules and the virtual gutting of Rule 38.1, Ariz. R. Civ. P.

Complaint AVOIDANCE OF FRAUDULENT TRANSFER PURSUANT TO 11 U.S.C. §§ 548, 550, AND 551
Matthew Kelly completes alcohol screening to avoid an Arizona Sate Bar complaint
Kimberly Celaya vs City of Goodyear, Arizona Federal Court
Lisa Huggins Hubbard Arizona Federal Bankruptcy City of Phoenix Neighborhood Specialist Kevin McCoy
Lisa Huggins Hubbard
7035 S. 19th Place
Phoenix, AZ 85042
City of Phoenix
Neighborhood Specialist
200 W. Washington
Phoenix, AZ 85003
Kevin McCoy
Matthew Kelly
Kelly-McCoy PLC