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

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

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Filed 04/27/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-1263-PSF-MEH ROBERT M. FRIEDLAND, Plaintiff, v. TIC ­ THE INDUSTRIAL COMPANY; GEOSYNTEC CONSULTANTS INC. f/k/a GEOSYNTEC, INC. Defendants.

DEFENDANT TIC'S UNOPPOSED MOTION FOR THREE-DAY EXTENSION OF TIME TO FILE ITS REPLY IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT

Defendant TIC ­ The Industrial Company ("TIC"), by and through its undersigned counsel, respectfully moves the Court for a three-day extension of time, to and including May 3, 2006, to file a Reply in Support of Motion for Summary Judgment ("Reply"). In support thereof, TIC states as follows: 1. 2. TIC filed a Motion for Summary Judgment on February 8, 2006. On March 31, 2006, Plaintiff filed his Response in Opposition to Defendant TIC ­

The Industrial Company's Motion for Summary Judgment ("Response"). Through an unopposed motion, the Plaintiff's deadline for the Response was extended from March 3, 2006, to March 31, 2006.

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

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3.

On February 16, 2006, this Court granted Defendant GeoSyntec a one-month

extension to file its reply to Plaintiff's response in opposition to GeoSyntec's motion for summary judgment. 4. Pursuant to D.C.Colo.LCivR 7.1(C), TIC's Reply was due on April 17, 2006.

This Court granted TIC's unopposed motion for an extension of time up to and including April 28, 2006, to file its Reply. 5. Due to the travel schedule of undersigned counsel, and difficulty obtaining certain

factual information, TIC requires an additional extension of three (3) business days to complete its Reply. 6. No party will be prejudiced by the delay. CERTIFICATIONS Pursuant to D.C.Colo.LCivR 7.1(A), counsel for TIC hereby certifies that he has conferred with Plaintiff's counsel, Kirk Mueller, and Mr. Mueller does not oppose the extension requested herein. Pursuant to D.C.Colo.LCivR 6.1(D), as set forth in the Certificate of Service, a copy of this motion has been served on the undersigned's client and all counsel of record.

WHEREFORE, for the foregoing reasons, Plaintiff respectfully requests that the Court extend the deadline to and including May 3, 2006, for TIC to file a reply to Plaintiff's Response.

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Respectfully submitted this 27th day of April 2006.

s/ Colin C. Deihl Colin C. Deihl, Esq. Faegre & Benson, LLP 3200 Wells Fargo Center 1700 Lincoln Street Denver, CO 80202-4532 Attorneys for Defendant TIC

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

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CERTIFICATE OF SERVICE I hereby certify that on this 27th day of April 2006, a true and correct copy of the foregoing DEFENDANT TIC'S UNOPPOSED MOTION FOR THREE-DAY EXTENSION OF TIME TO FILE ITS REPLY IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT was electronically filed via ECF with the U.S. District Court for the District of Colorado and served electronically or via first-class U.S. mail on the following: John D. Fognani, Esq. R. Kirk Mueller, Esq. Lauren C. Buehler, Esq. Fognani & Faught, PLLC 1700 Lincoln Street, Suite 2222 Denver, Colorado 80203 Terrence M. Ridley, Esq. Steven M. Kelso, Esq. Wheeler Trigg Kennedy, LLP 1801 California Street, Suite 3600 Denver, CO 80202-2617 Paul J. Sanner, Esq. Hanson, Bridgett, Marcus, Vlahos & Rudy, LLP 333 Market Street, Suite 2100 San Francisco, CA 94105-2122 Colin D. Reid Vice President/General Counsel TIC Holdings, Inc. 2211 Elk River Road P.O. Box 774848 Steamboat Springs, CO 80477

s/ Candee C. Smith
DNVR1:60343460.02