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

Case 1:04-cv-01271-EWN-BNB

Document 237

Filed 11/28/2006

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 04-cv-01271-EWN-BMB PATRICK M. HAWKINSON, Plaintiff, v. JAMES A. MONTOYA R. LYNN KEENER ROBERT SCRANTON, in their individual and official capacities, and ESTATE OF OPAL WILSON Defendants. ______________________________________________________________________________ MOTION TO ALLOW ADDITIONAL 30 DAYS TO RESPOND TO PLAINTIFF'S REQUEST FOR DISCOVERY / INTERROGATORIES ______________________________________________________________________________ COMES NOW, R. Lynn Keener, individually, Robert Scranton, individually and the Estate of Opal Wilson by and through the Personal Representative, R. Lynn Keener ("Amended Defendants"), by and through their attorney, and requests the court grant the Amended Defendant's addition time (30 days or until December 11, 2006) to answer Plaintiff's request for discovery and interrogatories as follows: 1. Plaintiff submitted to the Amended Defendant's various requests for discovery and interrogatories which were mailed on October 11, 2006. 2. Plaintiff has requested this court enter an order wherein Amended Defendants are deemed to have admitted Plaintiff's interrogatories.

Case 1:04-cv-01271-EWN-BNB

Document 237

Filed 11/28/2006

Page 2 of 3

3. Because of the holidays and the complicated nature of Plaintiff's requests, the Amended Defendants have not had sufficient time to respond to Plaintiff's discovery request in such a way to provide meaningful discovery. WHEREFORE, Amended Defendants respectfully request and enlargement of the time to respond to Plaintiff's discovery request and interrogatories by 30 days or until December 11, 2006. Respectfully submitted this 28th day of November, 2006.

ATTORNEY FOR THE AMENDED DEFENDANTS

By:__/s/_Robert J.M. Scranton_______________ Robert J.M. Scranton, 30638 (Colo.) Attorney for Amended Defendants R. Lynn Keener, Robert Scranton and the Estate of Opal Wilson 231 E. Vermijo Ave. Colorado Springs, CO 80903 (719) 477-0333

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Case 1:04-cv-01271-EWN-BNB

Document 237

Filed 11/28/2006

Page 3 of 3

CERTIFICATE OF SERVICE (CM/ECF) I HEREBY CERTIFY that on the 28th day of November, 2006, I electronically filed the forgoing MOTION TO ALLOW ADDITIONAL 30 DAYS TO RESPOND TO PLAINTIFF'S REQUEST FOR DISCOVERY / INTERROGATORIES with the Clerk of the Court using the CM/ECF system and hereby certify that I have mailed or served the foregoing document on the following non-CM-ECF participant(s) in the manner (mail, hand delivery, etc.) indicated by the non-participant's name: VIA U.S. MAIL: Patrick M. Hawkinson Reg. No. 62702 Arkansas Valley Correctional Facility P.O. Box 1000 Crowley, CO 81034 James A. Montoya c/o Cathie Holst Department of Corrections 2862 South Circle Drive Colorado Springs, CO 80906 By:__/s/_Robert J.M. Scranton_______________ Robert J.M. Scranton, 30638 (Colo.) Attorney for Amended Defendants R. Lynn Keener, Robert Scranton and the Estate of Opal Wilson 231 E. Vermijo Ave. Colorado Springs, CO 80903 (719) 477-0333

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