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

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

Document 193

Filed 06/16/2006

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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 REPLY TO DEFENDANT'S MEMORANDUM IN OPPOSITION TO PLAINTIFF'S AMENDED MOTION FOR CLASS CERTIFICATION

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 Unopposed Motion for Extension of Time to Reply to Defendant's Memorandum in Opposition to Plaintiff's Amended Motion for Class Certification, and as grounds therefore states as follows: Certificate of Compliance Pursuant to D.C.COLO.LCivR. 7.1(A) - Counsel for the Plaintiff has consulted with counsel for the Defendant regarding this Motion, and is authorized to state that the Defendant does not oppose the relief requested herein. 1. On April 4, 2006, Plaintiff filed a Motion for Class Certification, and on April

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

Document 193

Filed 06/16/2006

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14, 2006 Plaintiff filed an Amended Motion for Class Certification.

The Defendant

responded with a Memorandum in Opposition to Plaintiff's Amended Motion for Class Certification on June 1, 2006. Therefore, Plaintiff's Reply to Defendant's Response is due Friday, June 16, 2006. 2. An attorney in the office of Plaintiff's counsel who is actively involved in

this case is unexpectedly departing the firm, and that development has caused the Plaintiff to require an additional week to prepare the Reply. 3. Counsel for the Plaintiff therefore, requests a week extension of time up to

and including June 23, 2006 to file a Reply brief. 4. No party will be disadvantaged by this extension of time.

WHEREFORE, Plaintiff prays for an Order granting Plaintiff additional time up to and including June 23, 2006, in which to Reply to Defendant's Response. Respectfully submitted this 16th day of June, 2006.

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

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

Document 193

Filed 06/16/2006

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CERTIFICATE OF SERVICE I hereby certify that on this 16th day of June, 2006, 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]

And a copy was mailed to the following: Kelly Fincher 436 Longleaf Ct. O'Fallon, IL 62269 s/Robert B. Carey Robert B. Carey The Carey Law Firm

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