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

Case 1:04-cv-01263-REB-KLM

Document 51

Filed 01/18/2006

Page 1 of 4

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 04-cv- 1263- PSF- OES
ROBERT M. FRIEDLAND

Plaintiff

TIC - THE INDUSTRIAL COMPANY and GEOSYNTEC CONSULTANTS , INC. flk/a GEOSERVICES , INC.

Defendants.
GEOSYNTEC' S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT

Defendant GeoSyntec Consultants , Inc. , formerly GeoServices , Inc.
("GeoSyntec ) moves the Court for an extension of time , to and including February 15

2006 , within which to file a reply to Plaintiff's Response in Opposition to Defendant

GeoSyntec s Motion for Summary Judgment in the above-captioned matter. In support
thereof , GeoSyntec states:

CERTIFICATE OF COMPLIANCE WITH D.

COLO. LCivR 7. 1(A)

Undersigned counsel hereby certifies that she conferred with Plaintiff's counsel

regarding the extension requested herein. Plaintiff' s counsel indicated that Plaintiff
does not oppose this extension.

).
Case 1:04-cv-01263-REB-KLM Document 51 Filed 01/18/2006 Page 2 of 4

On November 18 , 2005 , GeoSyntec filed a Motion for Summary Judgment

(the " Motion ), arguing that based on undisputed facts , GeoSyntec is entitled to

judgment as a matter of law. With agreement from undersigned

counsel ,

Plaintiff was

granted two extensions of time , to January 10 , 2006 , within which to file a response to
the Motion.

On January 10 , 2006 , Plaintiff filed his Response in Opposition to

Defendant GeoSyntec s Motion for Summary Judgment (the " Response

Comprised

of 41 pages of text and 88 exhibits , the Response is voluminous.
Pursuant to D.

Colo. LCivR 7. 1 (C), GeoSyntec s reply to the Response is

currently due on January 25 , 2006. However , in order to fully address the factual

contentions and legal issues raised by the Response , GeoSyntec requires additional

time to prepare its reply to the Response.
GeoSyntec therefore requests a three-week extension of time , to and

including February 15 , 2006 , within which to file its reply to the Response.
Pursuant to D.

Colo. LCivR 6. 1 (D), undersigned counsel has served a

copy of this Motion on GeoSyntec s client representative , Paul Sanner , and on all
counsel of record as reflected in the certificate of service below.

WHEREFORE , Defendant GeoSyntec Consultants , Inc. respectfully requests an
order granting it an extension of time , to and including February 15 , 2006 , within which

to file a reply to Plaintiff's Response in Opposition to Defendant GeoSyntec s Motion for

Summary Judgment.

Case 1:04-cv-01263-REB-KLM

Document 51

Filed 01/18/2006

Page 3 of 4

Respectfully submitted this 18th day of January, 2006.

sf

Marian L. Carlson Marian L. Carlson
Terence M. Ridley
Wheeler Trigg Kennedy

LLP

1801 California Street , Suite 3600

Denver, CO 80202- 2617
Telephone No. : 303-292-2525
Telecopier No. : 303- 294- 1879

Mail: carlson~wtklaw. com
Attorneys for Defendant GeoSyntec Consultants , Inc

()
Case 1:04-cv-01263-REB-KLM Document 51 Filed 01/18/2006 Page 4 of 4

CERTIFICATE OF SERVICE
I hereby certify that on January 18 , 2006 , I electronically filed the foregoing

Unopposed Motion for Extension of Time to Respond to Plaintiff' s First Set of

Interrogatories and Requests for Production with the Clerk of Court using the CMfECF system which will send notification of such filing to the following email addresses:

Lauren C. Buehler Ibuehler~fognanilaw. com cvega~fognanilaw. com
Marian Lee Carlson carlson~wtklaw. com carpenter~wtklaw. com
Colin Christopher Deihl

Steven Matthew Kelso kelso~wtklaw. com hand~wtklaw. com

Richard Kirk Mueller rmueller~fognanilaw. com cvega~fognanilaw. com
Terence M. Ridley ridley~wtklaw. com norris~wtklaw. com

cdeihl~faegre. com jsullivan~faegre. com
Michael Stephen Freeman mfreeman~faegre. com

cdan iels~faegre. com

dcopeland~faegre. co

and I hereby certify that a copy of the document has been served to the following nonCMfECF participant in the manner indicated by the non- participant' s name:
Paul J. Sanner
( ) First

Counsel for GeoSyntec Consultants , Inc. Hanson , Bridgett , Marcus 333 Market Street , #2100 San Francisco , CA 94105- 2122
, Vlahos & Rudy,

Class Mail Hand Delivery

LLP

( ) Facsimile

Overnight Delivery (X) E- Mail

sf

Marian L. Carlson by Cindy Carpenter
LLP

Marian L. Carlson
Wheeler Trigg Kennedy

1801 California Street , Suite 3600

Denver, CO 80202- 2617 Telephone No. : 303-244- 1800 Telecopier No. : 303- 244- 1879 Mail: carlson~wtklaw. com
Attorney for Defendant GeoSyntec Consultants , Inc.