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

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

Document 201

Filed 08/26/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 01-CV-2089-MSK-CBS DEAN A. BRAMLET, M.D., Plaintiff, v. ASPEN VALLEY HOSPITAL DISTRICT, Defendant.

UNOPPOSED MOTION TO EXTEND TIME TO RESPOND TO PLAINTIFF'S MOTION IN LIMINE TO EXCLUDE TESTIMONY OF DEFENDANT'S EXPERT WITNESS DIANE DEWITT, PH.D.

Defendant Aspen Valley Hospital District (the "Hospital") respectfully submits this Unopposed Motion to Extend Time to Respond to Plaintiff's Motion In Limine to Exclude Testimony of Defendant's Expert Witness, Diane Dewitt, Ph.D. ("Motion"). In support of this Motion, the Hospital states as follows: 1. CERTIFICATION: The undersigned contacted counsel for the Plaintiff, Sander

Karp, who has no objection to the relief requested in this Motion. 2. On August 22, 2005, Plaintiff Dean A. Bramlet, M.D., filed a motion in limine to

exclude the testimony of the Hospital's expert witness, Diane DeWitt, Ph.D., at the trial of this matter, which is not scheduled to commence until June 12, 2006 ("Motion in Limine"). 3. 2005. The Hospital's response to the Motion in Limine is currently due September 12,

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

Document 201

Filed 08/26/2005

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4.

The daughter of the Hospital's counsel is getting married on September 24, 2005.

Due to scheduled vacation time to attend to final wedding plans, wedding-related events, and out-of-town guests and family, as well as commitments to other clients relating to other cases, the Hospital's counsel requests an extension of time, through October 14, 2005, to respond the Motion in Limine. 5. No party will suffer prejudice from the relief requested in this Motion and the

relief requested is not sought for purposes of harassment or delay. Dated this 26th day of August, 2005. Respectfully submitted,

s/Colleen M. Rea Colleen M. Rea, Esq. #024960 FORD & HARRISON LLP 1675 Broadway, Suite 2150 Denver, CO 80202 Telephone: (303) 592-8860 Facsimile: (303) 592-8861 E-Mail: [email protected] ATTORNEYS FOR DEFENDANT ASPEN VALLEY HOSPITAL DISTRICT

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

Document 201

Filed 08/26/2005

Page 3 of 3

CERTIFICATE OF MAILING (CM/ECF) I hereby certify that on August 26, 2005, I electronically filed the foregoing UNOPPOSED MOTION TO EXTEND TIME TO RESPOND TO PLAINTIFF'S MOTION IN LIMINE TO EXCLUDE TESTIMONY OF DEFENDANT'S EXPERT WITNESS DIANE DEWITT, PH.D., with the Clerk of Court using the CM/ECF system, which will send notification of such filing to the following e-mail addressee: Sander N. Karp, Esq.: [email protected]

s/ Colleen M. Rea Colleen M. Rea, (#024960 Ford & Harrison LLP 1675 Broadway, Suite 2150 Denver, CO 80202 Telephone: (303) 592-8860 Facsimile: (303) 592-8861 E-mail: [email protected] ATTORNEYS FOR DEFENDANT ASPEN VALLEY HOSPITAL DISTRICT
Denver:9847.1

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