Free Motion for Extension of Time - District Court of Colorado - Colorado

Case 1:01-cv-02089-MSK-CBS

Document 208

Filed 02/22/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 01-MK-2089-MSK-CBS DEAN A. BRAMLET, M.D., Plaintiff, v. ASPEN VALLEY HOSPITAL DISTRICT, Defendant. _____________________________________________________________________ PLAINTIFF'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO SUBMIT FINAL PRETRIAL ORDER _____________________________________________________________________ COMES NOW Plaintiff, Dean Bramlet, M.D., by and through his attorneys, Leavenworth & Karp, P.C., and respectfully moves the Court for an extension of time, through and including February 28, 2006, in which to submit the Final Pretrial Order to the Court. In support of this motion, Plaintiff states as follows: 1. The Court's Third Amended Scheduling Order set a Final Pretrial Conference

for March 2, 2006, and requested that the Final Pretrial Order be submitted to the Court no later than five days before the conference. 2. The parties are in the process of preparing the Final Pretrial Order. This

case involves complicated issues and extensive exhibits. For this reason and due to heavy press of business, Plaintiff respectfully requests an extension of time, through and including February 28, 2006, in which to submit the Final Pretrial Order.

I:\2006\Karp\Bramlet-0719\Pleadings\Mtn for ext of time to submit PTO.wpd

Case 1:01-cv-02089-MSK-CBS

Document 208

Filed 02/22/2006

Page 2 of 2

3.

No party will suffer prejudice nor has any other request for extension been

filed regarding this matter. 4. CERTIFICATION: The undersigned contacted counsel for the Defendant

Colleen Rea regarding the Motion, and is authorized to represent to the Court that counsel for the Defendant has no objection to the Motion. WHEREFORE, Plaintiff respectfully moves the Court for an extension of time, through and including February 28, 2006, in which to submit the Final Pretrial Order to the Court. LEAVENWORTH & KARP, P.C.

By:

s/Anna S. Itenberg Anna S. Itenberg 201 14th Street, Suite 200 Glenwood Springs, Colorado 81601 Tel. 970.945.2261 [email protected] Attorneys for Plaintiff

CERTIFICATE OF SERVICE I hereby certify that on the 22nd day of February, 2006, I electronically filed the foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME TO SUBMIT FINAL PRETRIAL ORDER with the Clerk of Court through CM/ECF system which will send notification of such filing to the following e-mail addresses: Colleen Rea at [email protected] s/Mary Lou Haflinger

I:\2006\Karp\Bramlet-0719\Pleadings\Mtn for ext of time to submit PTO.wpd