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

Case 1:01-cv-01315-REB-CBS

Document 134

Filed 03/12/2007

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Case No. 01-cv-1315-REB-CBS Leonard Baldauf, Plainitiff, v. Hyatt, et al., Defendant. ________________________________________________________________________ MOTION FOR EXTENSION OF TIME ________________________________________________________________________ The Plaintiff moves this Court for an Order extending the time in which to complete discovery and dispositive motion deadline and as grounds therefore states: 1. 2. 3. Counsel has accepted representation of plaintiff, Leonard Baldauf, pro se. Counsel entered his appearance on March 12, 2007. Counsel is presently scheduled to start a triple homicide, arson case on

March 19, 2007. This case is scheduled to last for six trial weeks. 4. Due to Counsel's trial schedule he would request that the discovery

deadline be moved to mid-May and a dispositive motion deadline sufficiently after that to allow the parties time to prepare their dispositive motions after the plaintiff's deposition has been taken in May, 2007. 5. this motion. Counsel has consulted with opposing counsel and there is no objection to

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Case 1:01-cv-01315-REB-CBS

Document 134

Filed 03/12/2007

Page 2 of 3

WHEREFORE the plaintiff prays that this Court enter and Order resetting the deadlines, previously set, in conformance with this motion and for such other and further relief as this Court seems appropriate. DATED this 23 rd day of January, 2007.

Respectfully submitted, s/ Dennis W. Hartley_____ Dennis W. Hartley, #788 Dennis W. Hartley, P.C. 1749 South 8th Street, Suite 5 Colorado Springs, CO 80906 Telephone: 719-635-5521 Fax: 719-635-5760 Email:[email protected] Attorney for Leonard Baldauf

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Case 1:01-cv-01315-REB-CBS

Document 134

Filed 03/12/2007

Page 3 of 3

CERTIFICATE OF SERVICE I certify that on this 23rd day of January, 2007 the foregoing motion was filed with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Andrew David Ringel at [email protected] Gillian Dale at [email protected] And to Judge Robert E. Blackburn at [email protected] And to Magistrate Craig B. Shaffer at [email protected]

s/ Lisa Schuler__ Lisa Schuler Paralegal to Dennis W. Hartley Dennis W. Hartley, P.C. 1749 South 8th Street, Suite 5 Colorado Springs, CO 80906 Telephone: 719-635-5521 Fax: 719-635-5760 E-mail:[email protected]

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