Free Motion for Extension of Time - District Court of Colorado - Colorado

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

Document 63

Filed 02/16/2006

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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 EXTENSION OF TIME

Defendant King Soopers, Inc. ("Defendant"), through its attorneys Sherman & Howard L.L.C., and pursuant to F.R.C.P. 6(b) and D.C.COLO.LCivR 7.1, files this Unopposed Motion For Extension of Time ("Motion") seeking to extend the deadline for Defendant to submit its Reply in Support of Defendant's Motion for Attorneys' and Expert's Fees. In support of this Motion, Defendant states as follows: 1. On January 26, 2006, a Minute Order was issued setting February 15, 2006 as the

deadline for Plaintiff to file a response to Defendant's Motion for Attorneys' and Expert's Fees ("Defendant's Motion"), and February 25, 2006 as the deadline for Defendant to file a reply in support of Defendant's Motion. 2. On February 14, 2006, a Minute Order was issued allowing Plaintiff an extension of

time, up to and including, February 20, 2006, to file her response to Defendant's Motion.

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

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Filed 02/16/2006

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3.

Accordingly, Defendant now seeks a corresponding extension of Defendant's deadline

to file its reply in support of Defendant's Motion, up to and including, March 2, 2006. 4. In accordance with D.C.COLO.LCivR 6.1C, Defendant has not sought any prior

extensions of Defendant's deadline to file its reply in support of Defendant's Motion. 5. In accordance with D.C.COLO.LCivR 7.1A, counsel for Defendant conferred with

Plaintiff's counsel, Jessica West, who stated that Plaintiff does not oppose this Motion. 6. In accordance with D.C.COLO.LCivR 6.1D, a copy of this Motion has been served

upon Plaintiff's counsel and Defendant. WHEREFORE, Defendant respectfully requests that the deadline for Defendant to file its reply in support of Defendant's Motion for Attorneys' and Expert's Fees, be extended, up to and including, March 2, 2006. Respectfully submitted this 16th day of February, 2006. SHERMAN & HOWARD L.L.C.

s/ Edward J. Butler Raymond M. Deeny Edward J. Butler 90 South Cascade Avenue, Suite 1500 Colorado Springs, CO 80903 (719) 475-2440/telephone (719) 635-4576/facsimile [email protected]; [email protected] Attorneys for Defendant

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

Document 63

Filed 02/16/2006

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CERTIFICATE OF SERVICE I hereby certify that on February 16, 2006, 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: [email protected] Jessica L. West, Esq. Smith & West, LLC 1860 Blake Street, Suite 420 Denver, CO 80202 I further certify that on February 16, 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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