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

Case 1:00-cv-02361-WDM-BNB

Document 44

Filed 04/16/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO JUDGE WALKER D. MILLER
C IVIL A CTION N O . 00-CV -02361-WDM-BNB (Consolidated with Nos. 00-cv-02362-WDM-BNB and 00-cv-02363-WDM-BNB; and 00-cv-02365-WDM-BNB, 00-cv-02366-WDM-BNB, 00-cv-02367WDM-BNB, 00-cv-02368-WDM-BNB, 00-cv-02369-WDM-BNB, 00-cv-02370-WDM-BNB, 00-cv02371-WDM-BNB, 00-cv-02372-WDM-BNB, 00-cv-02373-WDM-BNB, 00-cv-02374-WDM-BNB; and, 00-cv-02364-MJW-BNB and 00-cv-02394-MJW-BNB)

WYRICK G. DEANE, Plaintiff, v. MILTON TUCKER, et al., Defendants. _____________________________________________________________________________ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE A REPLY TO PITKIN COUNTY'S RESPONSE TO CONSOLIDATED OPENING BRIEF _____________________________________________________________________________ Plaintiff Wyrick G. Deane ("Deane") and defendants United States of America, Secretary of Agriculture, and the United States Forest Service (the "United States") jointly request a sevenday extension of time, or up to and including April 23, 2007, to file their reply to Pitkin County's Response to Consolidated Opening Brief, on the following grounds: 1. Deane and the United States filed their consolidated opening brief in support of

the proposed settlement on March 26, 2007. 2. 2007. 3. The United States' and Deane's consolidated reply brief is due April 16, 2007. Pitkin County filed its response to the consolidated opening brief on April 6,

Case 1:00-cv-02361-WDM-BNB

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4.

Deane and the United States jointly request a seven-day extension of time in

which to file their reply. Deane and the United States require this brief extension in order to consolidate and finalize their reply. 5. Counsel for the United States conferred with counsel for Pitkin County,

Christopher Seldin, and he stated that Pitkin County does not oppose the requested extension. WHEREFORE, the United States and Deane request that the Court grant them an extension of time, up to and including, April 23, 2007, in which to file their consolidated reply. TROY A. EID UNITED STATES ATTORNEY

s/Roxane J. Perruso Roxane J. Perruso Assistant United States Attorney 1225 17th Street, Suite 700 Denver, CO 80202 Telephone: 303-454-0127 FAX: 303-454-0404 E-mail: [email protected] Attorney for United States WELBORN SULLIVAN MECK & TOOLEY PC

s/Kathryn Haight Kathryn Haight 821 - 17th Street, Suite 500 Denver, Colorado 80202 Telephone: 303-830-2500 Facsimile: 303-832-2366 [email protected] Attorneys for Deane

Case 1:00-cv-02361-WDM-BNB

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Filed 04/16/2007

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO CERTIFICATE OF SERVICE (CM /ECF)

I hereby certify that on April 16, 2007, 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 J. Perruso Assistant U.S. Attorney 1225 17th Street, Suite 700 Denver, CO 80202 [email protected] John Michael Ely Pitkin County Attorney 530 East Main Street, #302 Aspen, CO 81611 [email protected] Christopher Giles Seldin Pitkin County Attorney's Office 530 East Main Street, #302 Aspen, CO 81611 [email protected]

and that I have mailed or served this document or paper to the following non CM/ECF participants via e-mail to the following nonparticipant: Via e-mail Helena Jones-Siddle, Esq. Office of the General Counsel USFS-USDA 740 Simms Street, Room 309 Golden, Colorado 80401 [email protected] s/Roxane J. Perrruso Roxane J. Perruso