May 5, 2013
Attorney David Kaminski stated during our telephone call last week that they freely gave me extensions and that having to plant was NOT good cause for an extension.
The FACTS: On 3/26 they agreed to an extension to 4/1, what a joke. Fortunately, the judge granted the extension to 4/14 despite their refusal.
From my 3/26/14 motion:
I am the Plaintiff Christine Baker and I hereby request that the Court extend the time to respond by April 14, 2014 to Defendants Midland Funding LLC’s and Midland Credit Management Inc.’s (“Midland”) March 10, 2014 Motion to Dismiss the 1nd Amended Complaint (doc. 71) because I am late with spring planting on our small organic farm.
Defendant Midland finally agreed to an extension to April 1, 2014, but I have to transplant and get my plants in the ground now and I’m simply too tired to research and work on my response at night after 12 hour work days.
Midland attorney Andrew Campbell's 3/26/14 email:
We can agree to an extension until April 1, 2014 to submit your response to the Motion for Judgment on the Pleadings.
C. Andrew Campbell
Campbell Law PC
1839 S. Alma School Road, Suite 275
Mesa, Arizona 85210
Fax (480) 838-9302
From: Christine Baker
Sent: Tuesday, March 25, 2014 10:21 PM
Subject: Baker v. Midland extension
Could you please have the courtesy to reply?
I'm late with spring planting on our organic farm and am requesting an extension to respond to your motion to dismiss until 4/14/14. Is that ok with you?
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