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

Case 1:04-cv-01227-MSK-PAC

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Filed 06/23/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-1227-MSK-PAC DAVID CORTNEY BISHOP, Plaintiff, v. UNITED PARCEL SERVICE, CO., a Delaware Corporation, Defendant. MOTION FOR EXTENSION OF TIME TO FILE PROPOSED PRETRIAL ORDER Defendant United Parcel Service, Co., by and through its counsel, Holland & Hart, LLP, requests a 1-day extension of time, up to and including June 27, 2005, in which to file the Joint Pretrial Order in the above-captioned matter. In support of this Motion, Defendant states as follows: 1. Pursuant to the Court's Order entered May 4, 2005, the Proposed Pretrial

Order is due on Friday, June 24, 2005. The Pretrial Conference in this matter is scheduled for Wednesday, June 29, 2005 at 1:30 p.m. 2. Counsel require this extension of time in order to finalize preparation of the

Proposed Pretrial Order. Plaintiff's counsel has assumed the leading role in preparation of the Order. At this time, Defendant's counsel has provided relevant portions of the Pretrial Order to Plaintiff, including a listing of Defendant's intended exhibits and witnesses. Counsel have reached substantial agreement with regard to the Proposed Pretrial Order; however, additional time is needed to finalize the proposed order and

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permit review by counsel for each party. 3. On information and belief, Plaintiff's counsel is presently attending a

conference outside the state of Colorado through at least Friday, June 24, 2005. In addition, undersigned counsel will be out-of-state on Friday, June 24, 2005. 4. No other extensions of time have been requested by the parties concerning

the Proposed Pretrial Order. 5. The granting of this Motion will neither prejudice any party nor delay any

proceeding before this Court. 6. As required by D.C.C OLO .L.C IV.R. 6.1(d), a copy of this Motion is being

served upon Defendant. 7. As required by D.C.C OLO .L.C IV.R. 7.1(a), the undersigned has attempted to

reach Plaintiff's counsel, Hollie Wieland, concerning this Motion via e-mail; however, such attempts have been unsuccessful. It is not believed that Plaintiff's counsel will oppose the granting of the relief requested herein. WHEREFORE, Defendant respectfully requests a 1-day extension of time, up to and including June 27, 2005, in which to file the Proposed Pretrial Order in this matter.

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Dated: June 23, 2005. Respectfully submitted,

s/Christie L. Ryan Christie L. Ryan, Esq. HOLLAND & HART LLP 90 S. Cascade Ave., Suite 1000 Colorado Springs, CO 80903-1645 (719) 475-6463 (719) 632-2461 fax [email protected] Jim Goh, Esq. HOLLAND & HART LLP 555 Seventeenth Street, Suite 3200 Denver, CO 80202 (303) 295-8000 (303) 295-8261 fax [email protected] ATTORNEYS FOR DEFENDANT UNITED PARCEL S ERVICE, C O.

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CERTIFICATE OF S ERVICE I hereby certify that on June 23, 2005, 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 via e-mail: Hollie L. Wieland Sears & Swanson, PC 2 North Cascade Ave., #1250 Colorado Springs, CO 80903

I further certify that on June 24, 2005, the following representative of Defendant were served a copy of the foregoing via U.S. Mail. Dena Hong, Esq. United Parcel Service Legal Department 55 Glenlake Parkway, N.E. Atlanta, GA 30328

s/Christie L. Ryan Christie L. Ryan, Esq. ATTORNEY FOR DEFENDANT HOLLAND & HART LLP 90 S. Cascade Ave., Suite 1000 Colorado Springs, CO 80903-1645 (719) 475-6463 (719) 632-2461 fax [email protected]

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-1227-MSK-PAC DAVID CORTNEY BISHOP, Plaintiff, v. UNITED PARCEL SERVICE, CO., a Delaware Corporation, Defendant. ORDER GRANTING EXTENSION OF TIME TO FILE PROPOSED PRETRIAL ORDER Having reviewed Defendant's Motion for Extension of Time to File Proposed Pretrial Order, and being advised in the premises, the Court ORDERS that the Motion be, and hereby is; GRANTED and that the Proposed Pretrial Order shall be due on June 27, 2005. DATED: ___________, 2005. BY THE COURT:

______________________________________ United States District Judge