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

Case 1:01-cv-02056-JLK

Document 52

Filed 07/06/2005

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Case 1:01-cv-02056-JLK

Document 52

Filed 07/06/2005

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The parties in Case No. 01-K-2056 respectfully request a final extension of time to complete discovery as follows:

1. Pursuant to the Court's order dated May 13, 2005 (Docket #51):

· The discovery cutoff date is July 29, 2005, · Rebuttal experts must be disclosed by June 20, 2005, and · The dispositive motion deadline is August 15, 2005

2. For the past several weeks, the parties have been actively completing depositions of percipient and expert witnesses.

3. Plaintiffs wish to designate one rebuttal expert witness, however, that witness has been unavailable to meet with plaintiffs' counsel and prepare a Rule 26 report. The proposed

rebuttal expert is now scheduled to meet with plaintiffs' counsel within the next seven days, and he can prepare a Rule 26 report by no later than July 15, 2005.

4. All other expert witnesses have been identified by the parties. The depositions of two expert witnesses have been completed, and the deposition of another expert witness has been started. The parties are actively engaged in scheduling the depositions of four other expert witnesses.

5. Due to various scheduling conflicts, the parties do not believe it will be possible to complete the depositions of all expert witnesses before July 29, 2005. /// /// Page 2
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Case 1:01-cv-02056-JLK

Document 52

Filed 07/06/2005

Page 3 of 4

6. Based on the foregoing, the parties jointly request that the Court enter an order extending the following deadlines:

· All rebuttal expert witness information shall be disclosed by July 15, 2005 · All discovery, including expert depositions, shall be completed by September 30, 2005 · Dispositive motions shall be filed and served no later than October 15, 2005

Respectfully Submitted, Dated: July 6 , 2005 s/ Jeffrey J. Williams Jon A. Kodani, Esq. Jeffrey J. Williams, Esq. LAW OFFICES OF JON A. KODANI Attorneys for Plaintiffs United States Aviation Underwriters, Inc. et al. 2200 Michigan Avenue Santa Monica, CA 90404-3906 Tel: (310) 453-6762 Fax: (310) 829-3340 Email: [email protected]

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Case 1:01-cv-02056-JLK

Document 52

Filed 07/06/2005

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CERTIFICATE OF SERVICE West Star Aviation / U.S. Aviation Underwriters et al. v. Omega Coating etc. et al. D.Colorado Case No. 1:05-cv-00346-REB-PAC [XXXXX] I hereby certify that on July 6, 2005 , I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: For Defendant Pratt & Whitney Thomas J. Byrne, Esq. Byrne, Kiely & White 1120 Lincoln Street, Suite 1300 Denver, CO 80203 Tel. (303) 861-5511 Fax (303) 861-0304 Email: [email protected] [email protected]

For Pilatus Defendants Robert B. Schultz, Esq. Law Offices of Robert B. Schultz 9710 W. 82nd Avenue Arvada, CO 80005 Tel. (303)456-5565 Fax (303)456-5575 Email: [email protected]

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I hereby certify that on , I have mailed or served the document or paper to the following non CM/ECF participants in the manner (mail, hand delivery, etc.) indicated by the nonparticipant's name: s/ Jeffrey J. Williams Jeffrey J. Williams, Esq. LAW OFFICES OF JON A. KODANI Attorneys for Plaintiffs United States Aviation Underwriters, Inc. et al. 2200 Michigan Avenue Santa Monica, CA 90404-3906 Tel: (310) 453-6762 Fax: (310) 829-3340 Email: [email protected]

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