Free Motion for Extension of Time to File Response/Reply - District Court of Colorado - Colorado

Case 1:01-cv-02313-JLK

Document 63

Filed 08/23/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 01-cv-2313-JLK-CBS GLN COMPLIANCE, INC., Plaintiff, v. UNITED AIRLINES, INC., d/b/a UNITED BIZ JET HOLDINGS, BIZ JET CHARTERS, INC., AND BIZ JET SERVICES, INC., and JONATHON ROSS, Defendants. __________________________________________________________________________ UNOPPOSED JOINT MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO PLAINTIFF'S MOTION TO LIFT ADMINISTRATIVE STAY __________________________________________________________________________ Defendants United Airlines, Inc., d/b/a United BizJet Holdings, BizJet Charter, Inc., and BizJet Services, Inc., ("United") and Jonathon Ross ("Ross"), by and through undersigned counsel, respectfully submit this Unopposed Joint Motion for Extension of Time to respond to Plaintiff's Motion to Lift Administrative Stay and state as follows: 1. Pursuant to Local Rule 7.1, counsel for United has conferred with counsel for

Plaintiff and confirmed that Plaintiff does not oppose this motion. 2. Defendants' Response to Plaintiff's Motion to Lift Administrative Stay is currently

due August 24, 2005. 3. Because the subject matter of Defendants' response involves bankruptcy issues

handled by separate bankruptcy counsel, Defendants request an additional 30 days, to and including September 23, 2005, within which to file a Response to Plaintiff's Motion to Lift Administrative Stay.

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Case 1:01-cv-02313-JLK

Document 63

Filed 08/23/2005

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4. 5.

The requested extension will not prejudice the Court or any party. Undersigned counsel certifies that a true and correct copy of this Motion was

served upon Plaintiffs' counsel, as well as a representative of United and Ross, individually. 6. convenience. WHEREFORE, Defendants respectfully request the Court to grant an extension of time, to and including September 23, 2005, within which to file a Response to Plaintiff's Motion to Lift Administrative Stay. Respectfully submitted this 23rd day of August, 2005. A proposed Order is filed contemporaneously herewith for the Court's

/s Amy E. Arlander Stephen D. Gurr Amy E. Arlander KAMLET SHEPHERD & REICHERT, LLP 1515 Arapahoe Tower One, Suite 1600 Denver, CO 80202 (303) 825-4200 [email protected] [email protected] ATTORNEYS FOR DEFENDANT JONATHAN ROSS

/s Mark T. Barnes Mark T. Barnes,
BROWNSTEIN HYATT & FARBER, P.C.

410 17th St., 22nd Floor Denver, CO 80202 (303) 223-1100 [email protected] ATTORNEYS FOR DEFENDANT UNITED AIR LINES, INC.

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Case 1:01-cv-02313-JLK

Document 63

Filed 08/23/2005

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CERTIFICATE OF SERVICE I hereby certify that on this 23rd day of August, 2005, I electronically filed the foregoing UNOPPOSED JOINT MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO PLAINTIFF'S MOTION TO LIFT ADMINISTRATIVE STAY with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail address: [email protected] [email protected] [email protected] I hereby certify that on this 23rd day of August, 2005, I served a true and correct copy of the attached UNOPPOSED JOINT MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO PLAINTIFF'S MOTION TO LIFT ADMINISTRATIVE STAY via the United States mail, postage pre-paid, properly addressed to: Ricks Fracier, Esq. United Air Lines, Inc. 1200 East Algonquin Road Elk Grove Township, Illinois 60007 Jonathan Ross c/o Stephen Gurr, Esq. KAMLET SHEPHERD & REICHERT, LLP 1515 Arapahoe Tower One, Suite 1600 Denver, CO 80202

/s Mark T. Barnes Mark T. Barnes BROWNSTEIN HYATT & FARBER, P.C. 410 17th Street, 22nd Floor Denver, Colorado 80202 Phone: (303) 223-1100 Fax: (303) 223-1111 E-mail:[email protected] ATTORNEYS FOR DEFENDANTS

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