Free Motion to Continue - District Court of Colorado - Colorado

Case 1:00-cv-02369-WDM-BNB

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Filed 07/26/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 00-cv-02369-WDM-OES WYRICK G. DEANE, Plaintiff, v. EDWARD CHARLTON, et al., Defendants.

JOINT MOTION TO CONTINUE ADMINISTRATIVE CLOSURES

Plaintiff, Wyrick G. Deane, and Defendant, the United States of America, through their respective counsel, hereby jointly request that an Order issue continuing the administrative closure of this case until December 31, 2005. 1. This quiet title action has been held in abeyance pursuant to orders of

administrative closure entered on March 26, 2002, July 31, 2003, and July 14, 2004, and is subject to being opened for good cause on or before July 29, 2005.1 2. The Plaintiff and the United States have engaged in settlement discussions and

have reached settlements, in principle, as to this action, subject to approval by the Department of Justice and the U.S. Forest Service. If the proposed settlement is approved and concluded, this action will be dismissed in its entirety upon the motion of the parties on or before December 31, 2005.

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See July 14, 2004 Order, D. Colo. Case No. 00-cv-02355-WDM-OES, et seq.

Case 1:00-cv-02369-WDM-BNB

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Filed 07/26/2005

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3.

The additional time requested herein is necessary in order to allow the approving

agencies of the federal government adequate time to evaluate the terms of the proposed settlement. Respectfully submitted this 26th day of July, 2005.

WELBORN SULLIVAN MECK & TOOLEY PC ____________________________ s/Kathryn Haight Suite 500 821 17th Street Denver, CO 80202 Tel. 303-830-2500 Fax 303-832-2366 [email protected] for Plaintiff

WILLIAM J. LEONE ACTING UNITED STATES ATTORNEY _____________________________ s/Roxane J. Perruso Assistant United States Attorney U.S. Attorney's Office 1225 17th Street, Suite 700 Denver, CO 80202 Tel. 303-454-0127 Fax 303-454-0404 [email protected] for United States of America

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Case 1:00-cv-02369-WDM-BNB

Document 19

Filed 07/26/2005

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on July 26, 2005, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following email addresses: Roxane Perruso Assistant U.S. Attorney Attorney for Defendant [email protected] and I hereby certify that I have mailed or served the document or paper to the following non CM/ECF participants in the manner (mail, hand- delivery, etc.) indicated above the nonparticipant's name: Via E-Mail Helena Jones-Siddle, Esq. Office of the General Counsel USFS-USDA 740 Simms Street, Room 309 Golden, CO 80401 [email protected]

s/Kathryn Haight Welborn Sullivan Meck & Tooley, PC Attorney for Plaintiff 821 17th Street, Suite 500 Denver, CO 80202 Phone: 303-830-2500 [email protected]

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