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

Case 1:04-cv-01214-PSF-OES

Document 61

Filed 09/15/2005

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04cv01214-PSF- OES KATHLEEN M. TOWERS, Plaintiff, vs. SAFEWAY INC., Defendant.

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY BRIEF IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT
Defendant, Safeway Inc. ("Safeway"), by and through its attorneys HOLLAND & HART LLP , respectfully moves for a one- week extension of time to and including September 22, 2005, in which to submit its reply brief in support of motion for summary judgment. As grounds therefore, Safeway states as follows: 1. Safeway's brief in support of its motion for summary judgment is

currently due on September 15, 2005. 2. Defendant has been diligently preparing its brief. However, due to the

intervening holiday and several unavoidable conflicts including trial preparation in the case of David Cortney Bishop v. United Parcel Service, Inc., 04cv01227- MSK- PAC, counsel for Safeway requires additional time to complete the brief. 3. Pursuant to D.C.Colo.LCivR 6.1(d), a co py of this motion is being served

on Defendant.

Case 1:04-cv-01214-PSF-OES

Document 61

Filed 09/15/2005

Page 2 of 3

5.

Pursuant to D.C.Colo.LCivR 7.1, undersigned counsel conferred with

Plaintiff's counsel, Robert Truhlar, on September 15, 2005 and is authorized to represent that Plaintiff has no objection to the relief requested in this motion. WHEREFORE, Defendant Safeway Inc. respectfully requests an extension of time to and including September 22, 2005 to submit its reply brief in support of its motion for summary judgment. Dated: September 15, 2005. s/Emily Hobbs- Wright Jim Goh Emily Hobbs- Wright HOLLAND & HART LLP 555 ­ 17th Street, Suite 3200 Denver, CO 80202 (303) 295-8584 Fax No.: (303) 672-6505 [email protected] [email protected] ATTORNEYS FOR DEFENDANT SAFEWAY INC.

2

Case 1:04-cv-01214-PSF-OES

Document 61

Filed 09/15/2005

Page 3 of 3

CERTIFICATE OF SERVICE

I hereby certify that on September 15, 2005, I electronically filed 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]

s/Emily Hobbs- Wright Emily Hobbs- Wright Holland & Hart LLP 555 ­ 17th Street, Suite 3200 P. O. Box 8749 Denver, CO 80202 (303) 295-8166; (303) 295- 8584 Fax No. (303) 672-6505 ehobbs- [email protected]

3451372_1.DOC

3