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

Case 1:01-cv-01857-RPM-MJW

Document 114

Filed 08/15/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 01-cv-01857-RPM-MJW ATTORNEYS TITLE GUARANTY FUND, INC. as successor in interest and assignee of Joseph H. Fallon, IV Plaintiff, v. PROLAND MANAGEMENT, LLC; CRAIG NELSON; TOM WARNES; and ROBERT R. SURLES, Defendants.

SECOND UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO MOTION FOR SUMMARY JUDGMENT

Defendants Proland Management, LLC, Craig Nelson and Tom Warnes (the "Defendants") by their undersigned counsel, move the Court for an Order extending to and including August 17, 2005, the time within which may the Defendants may respond to Plaintiff's Motion for Summary Judgment As grounds for the relief requested, the Defendants state as follows: 1. The undersigned counsel hereby certifies that he has conferred with counsel for Plaintiff and he is authorized to state that counsel for Plaintiff does not oppose the relief requested herein. Undersigned counsel further submits that consultation with any other party is not necessary to or required for the relief requested herein. 2. No prejudice to any party will result from the brief extension of time sought herein.

3. Although counsel has previously sought an extension of time to respond to the Motion for Summary Judgment, the aggregate of the time sought in the prior motion and the time sought in this Motion is less than ten (10) days.

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Case 1:01-cv-01857-RPM-MJW

Document 114

Filed 08/15/2005

Page 2 of 2

Wherefore, the Defendants, by their undersigned counsel, move the Court for an Order extending to and including August 17, 2005, the time within which the Defendants may respond to the Motion for Summary Judgment. Dated: August 15, 2005 Respectfully submitted, THOMAS F. QUINN, P.C.

s/ Thomas F. Quinn By: ______________________________________ Thomas F. Quinn THOMAS F. QUINN, P.C. 1600 Broadway Ste 1675 Denver CO 80202 Telephone: 303.832.4355 Fax: 303.672.8281 Email: [email protected] Counsel for Defendants Craig Nelson Tom Warnes and Proland Management LLC CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing SECOND UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO MOTION FOR SUMMARY JUDGMENT was served upon the Defendants by electronic transmission through the ECF filing system on this 15th day of August, 2005: BALDWIN & CARPENTER Stacy A. Carpenter, Esq. [email protected] Tory A. Riter, Esq. [email protected] s/ Deanna J. Staab __________________________________________

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