Free Motion for Leave - District Court of Colorado - Colorado

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

Document 69

Filed 03/03/2006

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 00-CV-02350-LTB-MJW PAULETTE GOMEZ, Plaintiff, v. KING SOOPERS, INC., Defendant.

PLAINTIFF'S UNOPPOSED MOTION FOR LEAVE TO FILE A REPLY TO DEFENDANT'S REPLY IN SUPPORT OF MOTION FOR ATTORNEYS' AND EXPERT'S FEES

Plaintiff, Paulette Gomez, through counsel, requests permission to file the attached Plaintiff's Reply to Defendant's Reply in Support of Defendant's Motion for Attorneys' and Expert's Fees ("Surreply," attached as Exhibit A). In Defendant's Reply of March 2, 2006, Defendant accuses Ms. Gomez of lying in her sworn declaration filed in support of Plaintiff's Response of February 20, 2006. Ms. Gomez desires to clarify the statements at issue, particularly in light of the fact that Defendant's claim is based, in part, on having confused her with unrelated individuals. Because of the severity of the relief sought by Defendant, Plaintiff respectfully requests that she be allowed to file the attached Surreply.

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

Document 69

Filed 03/03/2006

Page 2 of 3

CERTIFICATION OF COMPLIANCE WITH D.C.COLO.L.Civ.R. 7.1(A) Pursuant to D.C.COLO.L.Civ.R. 7.1, counsel for Plaintiff has conferred with Defendant's counsel, who does not oppose the filing of the Surreply requested herein.

DATED: March 3, 2006 Respectfully submitted, SMITH & WEST, LLC ______s/Jessica L. West_____ Jessica L. West, Esq. Blake Street Terrace 1860 Blake Street, Suite 420 Denver, Colorado 80202 (303) 391-0100/Telephone (303) 391-0102/Facsimile [email protected] Attorneys for Plaintiff

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

Document 69

Filed 03/03/2006

Page 3 of 3

CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 3rd day of March, 2006, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following email addresses: [email protected] [email protected] ______s/Jessica L. West______ Jessica L. West, Esq. Smith & West LLC Blake Street Terrace 1860 Blake Street, Suite 420 Denver, Colorado 80202 (303) 391-0100/Telephone (303) 391-0102/Facsimile [email protected]