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

Case 1:00-cv-02098-REB-MJW

Document 213

Filed 03/15/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 00-cv-02098-REB-MJW KELLY FINCHER, by her guardian, JAMES FINCHER, on behalf of herself and all others similarly situated, Plaintiffs, v. PRUDENTIAL PROPERTY AND CASUALTY INSURANCE COMPANY, a New Jersey Corporation, Defendant.

PLAINTIFF'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO SUBMIT SUPPLEMENTAL FED.R.CIV.P. 26(a)(2) DISCLOSURES Rule 7.1 Certification ­ Counsel for Plaintiffs has conferred with counsel for Defendant concerning this motion, and Defendant does not oppose the relief requested._________________________________________________________ Plaintiff, KELLY FINCHER, by her guardian, JAMES FINCHER, on behalf of herself and all others similarly situated, by and through her attorneys of record, The Carey Law Firm, submits the following Motion for Extension of Time to Submit Supplemental Fed.R.Civ.P. 26(a)(2) Disclosures: 1. Pursuant to the Amended Scheduling Order dated September 14,

2006 (Document 202), any supplemental disclosures pursuant to Fed.R.Civ.P. 26(a)(2) are due March 15, 2007. 2. Plaintiff intends to supplement the report of Jerome Sherman,

Ph.D. regarding Plaintiff's economic condition; however, Plaintiff's counsel has been completely occupied in preparing for and participating in a five-day jury trial in Hudgins v. Financial Indemnity Company, No. 2003CV1295, currently

Case 1:00-cv-02098-REB-MJW

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proceeding in Denver District Court; and therefore has been unable to successfully complete consultation with Dr. Sherman. 3. Therefore, a brief, two-week extension of time to submit

supplemental expert disclosures, to and including March 29, 2007, is requested. 4. Plaintiff anticipates that the supplement will only consist of revising

figures to make them timely in light of the upcoming trial date, and not posit any new theory or development. Therefore, none of the parties will be prejudiced by the relief requested herein, and counsel for Defendant does not oppose the requested relief. WHEREFORE, the Plaintiff, Kelly Fincher, requests that this Court enter an order granting an extension of time to and including March 29, 2007, for Plaintiff to submit her supplemental expert disclosures.

Respectfully submitted this March 15, 2007.

s/Leif Garrison Robert B. Carey Leif Garrison The Carey Law Firm 2301 East Pikes Peak Ave. Colorado Springs, Colorado 80909 Phone: (719) 635-0377 Fax: (719) 635-2920 Email: [email protected]

Steve W. Berman, WSBA #12536 HAGENS BERMAN, L.L.P. 1301 Fifth Avenue, Suite 2900 Seattle, WA 98101

Case 1:00-cv-02098-REB-MJW

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L. Dan Rector
FRANKLIN D. AZAR & ASSOCIATES, PC

5536 Library Lane Colorado Springs, CO 80918 Attorneys for Plaintiffs

CERTIFICATE OF SERVICE I hereby certify that on this March 15, 2007, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF System, which will send notification to the following email addresses: [email protected] Additionally, a copy was mailed to the following: Kelly Fincher 436 Longleaf Ct. O'Fallon, IL 62269 s/Leif Garrison Robert B. Carey Leif Garrison The Carey Law Firm 2301 East Pikes Peak Ave. Colorado Springs, Colorado 80909 Phone: (719) 635-0377 Fax: (719) 635-2920 Email: [email protected]

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