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

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

Document 51

Filed 08/10/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 04-cv-01214-PSF-0ES

KATHLEEN M. TOWERS, Plaintiff, v. SAFEWAY INC., Defendant.

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE A RESPONSE BRIEF TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT, AND CERTIFICATION

Plaintiff Kathleen M. Towers ("Towers") by her attorneys, Truhlar and Truhlar, L.L.P. and specifically Robert J. Truhlar, hereby moves the Court for a one-week extension of time to and including August 31, 2005, in which to submit her brief in response to Defendant Safeway's Motion and Brief in support of its motion for summary judgment. As grounds therefore, Plaintiff states as follows: 1. Plaintiff's brief responding to Safeway's motion for summary judgment is

currently due on August 24, 2005. 2. Due to conflicts with other scheduled business and summer schedules, Plaintiff

anticipates needing 7 additional days to complete her brief. 3. The parties to this case will not be prejudiced.

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

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4.

The undersigned has conferred with Defendant's counsel, Emily Hobbs-Wright,

in accordance with D.C.Colo.LCivR 7.1(A) and is authorized to represent that Defendant has no objection to the relief requested in this motion. 5. Pursuant to D.C.Colo.LCivR 6.1(D), counsel for the Plaintiff is sending a copy of

this motion for an extension to the Plaintiff who does not object to it.

WHEREFORE, the Plaintiff requests the Court for a one-week extension of time to and including August 31, 2005, in which to submit her brief responding to Defendant Safeway's Motion and Brief in support of its motion for summary judgment. Dated this 10th day of August 2005

TRUHLAR and TRUHLAR, L.L.P.

s/ Robert J. Truhlar____________ Robert J. Truhlar 7340 E. Caley Ave., Suite 310 Centennial, CO 80111 Telephone: (303) 794-2404 Facsimile: (303) 794-1142 ATTORNEY FOR THE PLAINTIFF

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

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CERTIFICATE OF SERVICE I hereby certify that on August 10, 2005, I electronically filed the foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE A RESPONSE BRIEF TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT AND CERTIFICATION 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] [email protected] s/ Robert J. Truhlar____________ Robert J. Truhlar 7340 E. Caley Ave., Suite 310 Centennial, CO 80111 Telephone: (303) 794-2404 Facsimile: (303) 794-1142

The undersigned hereby certifies that on this 10th day of August 2005, I caused a true and correct copy of the foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE A RESPONSE BRIEF TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT AND CERTIFICATION was deposited in the United States mail to the plaintiff:

Kathleen Towers 2451 East 116th Way Thornton, CO 80220 s/ Gregory Boucher__________ Gregory Boucher

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