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6998908.1

Gordon Lewis, Bar #015162

David C. Potts, Bar #030550

JONES, SKELTON & HOCHULI, P.L.C.

40 North Central Avenue, Suite 2700

Phoenix, Arizona 85004

Telephone: (602) 263-1700

Fax: (602) 200-7829

glewis@jshfirm.com

dpotts@jshfirm.com

Attorneys for Defendants Global Logistics 

Support Services, Inc.

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

Curtis “Wayne” Pritchett,

Plaintiff,

v.

SS/Global Logistics Support SV,

Defendants.

NO. CV-17-04442-PHX-GMS

Defendant Global Logistics Support 

Services, Inc.’s Motion for Leave to 

File Motion for Summary Judgment

Defendant Global Logistics Support Services, Inc. (“Global Logistics”), by 

and through counsel undersigned, hereby moves for leave to file its motion for summary 

judgment in this matter.

Though discovery is still ongoing in this matter, Global Logistics has taken 

Plaintiff’s deposition. Based on this deposition and the other completed discovery, Global 

Logistics believes it has a basis for summary judgment on Plaintiff’s only remaining claim 

for worker’s compensation retaliation.

The Case Management Order (Docket No. 30) provides:

The Court will hold a conference with the parties before 

motions for summary judgment are filed. The purpose of the 

conference will be to narrow issues and focus the briefing, and 

perhaps dispense with statements of fact under Local Rule 

56.1. The parties shall exchange two-page letters describing 

any anticipated motions for summary judgment and responses, 

identifying the issues and claims on which summary judgment 

will be sought and the basis for the motions and response. The 

parties shall file these letters with the Court on or before 

Case 2:17-cv-04442-SMM Document 34 Filed 08/30/18 Page 1 of 3
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6998908.1 2

January 4, 2019, and shall call the Court the same day to 

schedule a time for a pre-motion conference.

On August 2, 2018, counsel for Global Logistics sent Plaintiff Curtis 

Pritchett explaining Global Logistics’ anticipated motion for summary judgment, the 

issues and claims on which summary judgment will be sought, and the basis for the 

motion. Counsel also offered Plaintiff the opportunity to voluntarily dismiss this litigation. 

Plaintiff declined this offer and insisted his termination was wrongful. A copy of this email exchange is attached as Exhibit A to this motion.

Given this, Global Logistics has satisfied the requirements of the Court’s 

order and attempted to avoid the need for a motion for summary judgment. As a result, 

Global Logistics requests that it be permitted leave to file its motion for summary 

judgment prior to the pre-trial conference contemplated by the Court’s Case Management 

Order to allow the issue (and therefore the case) to be decided speedily and inexpensively.

DATED this 30th day of August 2018.

JONES, SKELTON & HOCHULI, P.L.C.

By /s/ David C. Potts

Gordon Lewis

David C. Potts

40 North Central Avenue, Suite 2700

Phoenix, Arizona 85004

Attorneys for Defendants Global Logistics 

Support Services, Inc.

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6998908.1 3

CERTIFICATE OF SERVICE

I hereby certify that on this 30th day of August 2018, I caused the 

foregoing document to be filed electronically with the Clerk of Court through the 

CM/ECF System for filing; and served on counsel of record via the Court’s CM/ECF 

system.

I further certify that some of the participants in the case are not registered 

CM/ECF users. I have mailed the foregoing document to the following non-CM/ECF 

participants:

Curtis “Wayne” Pritchett

8641 S Avenue D

Yuma, Arizona 85364

Pro Per

/s/ S. Coffey

Case 2:17-cv-04442-SMM Document 34 Filed 08/30/18 Page 3 of 3