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

Case 1:01-cv-02056-JLK

Document 101

Filed 12/22/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Judge John L. Kane

Civil Action No. 01-cv-2056-JLK-MJW UNITED STATES AVIATION UNDERWRITERS, INC., a New York corporation; PAUL LEADABRAND, an Idaho resident; and JEFLYN AVIATION, INC. d/b/a ACCESS AIR, an Idaho corporation, Plaintiffs, vs. PILATUS BUSINESS AIRCRAFT, LTD., a Colorado corporation; PILATUS FLUGZEUGWERKE AKTIENGESELLSCHAFT, a Swiss corporation; PILATUS AIRCRAFT, LTD., a Swiss corporation; PRATT & WHITNEY CANADA, INC., a Canadian corporation; and DOES 1 through 500, Inclusive, Defendants.

DEFENDANTS' UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE DAUBERT MOTIONS

The Defendants, by their attorneys, move the Court for an additional extension of time within which to file their Daubert motions and the associated responses and replies pursuant to Fed.R.Civ.P. 6(b) and D.C.COLO.LCivR 6.1, and as grounds therefor state as follows: 1. Counsel for all parties concur in this Motion. The attorneys for Defendant Pratt &

Whitney Canada Corp. ("PWC") have conferred with all other counsel before filing this motion in accordance with D.C.COLO.LCivR 7.1A and were advised that all parties concur with the requested extension of time.

Case 1:01-cv-02056-JLK

Document 101

Filed 12/22/2006

Page 2 of 3

2.

Pursuant to the Court's Order of December 15, 2006, the deadline to file Daubert

motions had already been extended to today, December 22, 2006. Defendants now request an additional extension of one week to and including December 29, 2006 within which to file Daubert motions. 3. Defendants and Plaintiffs also request that the corresponding deadlines for

response and reply be similarly extended. Currently, the Daubert motion response deadline is January 12, 2007 and the Daubert motion reply deadline is January 22, 2007. The parties request that these dates be extended to January 19, 2007 and January 29, 2007, respectively. 4. Defendants respectfully request this extension of time to file these motions

because they have been unable to complete these motions within the current schedule due to the effects of blizzard that struck Denver, Colorado during the week of December 22, 2006. 5. Copies of this Motion have been served on PWC and all counsel of record in accordance with D.C.COLO.LCivR 6.1.D. WHEREFORE, Defendants respectfully request that the Court extend the time within which to file Daubert motions and the associated responses and replies. Respectfully submitted this 22nd day of December 2006. /s/ Thomas J. Byrne Thomas J. Byrne William White BYRNE, KIELY & WHITE, L.L.P. 1120 Lincoln Street, Suite 1300 Denver, CO 80203 Telephone: (303) 861-5511 Attorneys for Defendant Pratt & Whitney Canada Corp.

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Case 1:01-cv-02056-JLK

Document 101

Filed 12/22/2006

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CERTIFICATE OF SERVICE I hereby certify that on this 22nd day of December 2006, I caused the foregoing DEFENDANTS' UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE DAUBERT MOTIONS to be served by electronically filing the foregoing with the Clerk of Court using the CM/ECF system, which will send notification of such filing to the following email addresses: Jon A. Kodani, Esq. Jeffrey J. Williams, Esq. LAW OFFICES OF JON A. KODANI [email protected] Robert B. Schultz, Esq. LAW OFFICES OF ROBERT B. SCHULTZ [email protected] and by electronic mail to: Mr. Ron Ortuso PRATT & WHITNEY CANADA CORP. [email protected]

/s/ Kevin R. Kennedy

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