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

Case 1:04-cv-01233-WYD-MEH

Document 21

Filed 06/30/2005

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-1233-WYD-OES KAREN GLOSSOP and DAVID GLOSSOP, Plaintiffs, vs. PAUL MEDINA, Defendant. _____________________________________________________________________________ UNOPPOSED MOTION TO EXTEND EXPERT WITNESS DEADLINES _____________________________________________________________________________ COME NOW the Defendant in this matter and respectfully request the Court extend deadlines for expert reports and discovery sixty (60) days for all parties. In support of said motion the parties would state as follows: 1. The parties have aggressively worked to complete lay witness discovery and begin expert witness discovery. The deposition of the Plaintiffs was completed on June 21, 2005, three IME exams were performed the week of June 20, 2005. 2. Due to difficulties and delays in receiving employment and medical records, summer vacation of experts it is anticipated that there will be delays in obtaining reports. in order to meet the present scheduling order. 3. claims. 4. In addition, the parties have agreed to attend the mediation August 18, 2005, after expert reports are exchanged, the parties do not wish to incur costs for depositions of expert witnesses prior to mediation. In order to facilitate this schedule it has been mutually agreed to by all parties, the parties request the Court extend deadlines for all expert designation 60 days for each party and the Court extend the deadline for expert witness discovery 60 days for each party. Further, Plaintiff is also in need of additional time for experts regarding damages

Case 1:04-cv-01233-WYD-MEH

Document 21

Filed 06/30/2005

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Respectfully submitted by the parties:

SCHNELL & D'ANTUONO

WHITE and STEELE, P.C.

By:

s/ Donald F. D'Antuono By: Donald F. D'Antuono, Esq. SCHNELL & D'ANTUONO 1660 Lincoln Street, Suite 1660 Denver, CO 80264 [email protected] Telephone: (303) 830-8800 Fax: (303) 830-8850 Attorney for Plaintiffs Karen Glossop and David Glossop

s/ John P. Craver John P. Craver White and Steele, P.C. 950 17th Street, Suite 2100 Denver, Colorado 80202 Telephone: (303) 296-2828 Fax: (303)296-3131 E-mail: [email protected] Attorney for Defendant Paul Medina

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Case 1:04-cv-01233-WYD-MEH

Document 21

Filed 06/30/2005

Page 3 of 3

CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on this 30th day of June, 2005, I electronically file the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: [email protected]

WHITE and STEELE, P.C.

By:

s/ John P. Craver John P. Craver White and Steele, P.C. 950 17th Street, Suite 2100 Denver, Colorado 80202 Telephone: (303) 296-2828 Fax: (303)296-3131 E-mail: [email protected] Attorney for Defendant Nationwide Mutual Insurance Company

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