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

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

Document 100

Filed 10/05/2005

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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. UNOPPOSED MOTION FOR EXTENSION OF TIME FOR SUBMISSION OF STIPULATION FOR DISMISSAL Defendant United Parcel Service Co. respectfully requests a 3-day extension of time, up to and including October 6, 2005, for the parties to submit a stipulation for dismissal of this matter. As grounds, UPS states as follows: CERTIFICATE OF COMPLIANCE WITH D.C.Colo.LCivR 7.17.1 The undersigned certifies that she has conferred with counsel for Plaintiff and that Plaintiff's counsel is unopposed to the Court granting the relief requested by this Motion. 1. In accordance with D.C.Colo.LCivR 6.1(C), this is the first request by the

parties for an extension of time to submit a stipulation for dismissal. 2. UPS. Pursuant to D.C.Colo.LCivR 6.1(D) this Motion has been served upon

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

Document 100

Filed 10/05/2005

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3.

Pursuant to discussions held before this Court on September 19, 2005, the

parties have reached a verbal resolution of this matter, eliminating the necessity of trial. The parties require additional time, however, to finalize an agreement reflecting that resolution. 4. The parties do not anticipate requesting any further extension of time for

filing of a stipulation of dismissal. WHEREFORE, UPS respectfully requests a 3-day extension of time, up to and including October 6, 2005, for the parties to submit a stipulation for dismissal of this matter. Dated October 5, 2005. Respectfully submitted,

s/Christie L. Ryan Christie L. Ryan, Esq. HOLLAND & HART LLP 90 S. Cascade, Ste. 1000 Colorado Springs, CO 80903 (719) 475-6463 (719) 634-2461 fax [email protected] ATTORNEYS FOR DEFENDANT United Parcel Service

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

Document 100

Filed 10/05/2005

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CERTIFICATE OF SERVICE I hereby certify that on October 5, 2005, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification to all counsel of record.

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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