Free Motion to Stay - District Court of Colorado - Colorado

Case 1:00-cv-02350-LTB-MJW

Document 72

Filed 03/06/2006

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THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 00-cv-2350-LTB-MJW PAULETTE GOMEZ, Plaintiff, v. KING SOOPERS, INC., Defendant.

DEFENDANT'S UNOPPOSED MOTION FOR STAY ON DEFENDANT'S MOTION FOR ATTORNEYS' AND EXPERT'S FEES

Defendant King Soopers, Inc. ("Defendant"), through its attorneys, Sherman & Howard L.L.C., and pursuant to D.C.COLO.LCivR 6.1 and 7.1, files this Unopposed Motion For Stay on Defendant's Motion for Attorneys' and Expert's Fees, and in support thereof states as follows: 1. On January 24, 2006, Defendant filed its Motion for Attorneys' and Expert's Fees

("Defendant's Motion"). Defendant's Motion has been fully briefed and is pending before the Court. 2. The parties currently are in active settlement discussions and anticipate that within

a week, they will reach an agreement as to a settlement that will dispose entirely of this matter. Accordingly, Defendant seeks a fourteen (14) day stay of a decision on Defendant's Motion, up to and including, March 20, 2006. This stay is needed so that the parties can complete their settlement discussions and the settlement process, and file an appropriate motion with the Court seeking dismissal of this case.

Case 1:00-cv-02350-LTB-MJW

Document 72

Filed 03/06/2006

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3.

In accordance with D.C.COLO.LCivR 7.1A, counsel for Defendant has conferred

with Plaintiff's counsel, who stated Plaintiff does not oppose this Motion. 4. In accordance with D.C.COLO.LCivR 6.1D, a copy of this Motion has been served

upon Plaintiff's counsel and Defendant. WHEREFORE, for the reasons set forth above, Defendant respectfully requests a fourteen (14) day stay of a decision on Defendant's Motion for Attorneys' and Expert's Fees, up to and including, March 20, 2006. Respectfully submitted this 6th day of March, 2006. SHERMAN & HOWARD L.L.C.

s/ Edward J. Butler Raymond M. Deeny Edward J. Butler 90 South Cascade Avenue, Suite 1500 Colorado Springs, Colorado 80903 (719) 475-2440 Attorneys for Defendant

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Case 1:00-cv-02350-LTB-MJW

Document 72

Filed 03/06/2006

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on March 6, 2006, a true and correct copy of the foregoing was electronically filed with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: [email protected] Jessica L. West, Esq. Smith & West, LLC Blake Street Terrace 1860 Blake Street, Suite 420 Denver, CO 80202 I further certify that on March 6, 2006, a true and correct copy of the foregoing document was deposited in the U.S. Mail, postage prepaid, addressed to the following: Ms. Stephanie Bouknight King Soopers, Inc. P.O. Box 5567, T.A. Denver, CO 80217 s/ Peggy J. Barber, Secretary to Edward J. Butler

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