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

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

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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 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 August 1, 2005, in which to submit its 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 July 25, 2004. 2. Defendant has been diligently preparing its brief. However, due to several

depositions in United Stated District Court Civil Action Nos. 04cv00423- WYD-MJW, Honeycutt et al. v. Safeway Inc ., 05cv00114- EWN-PAC, John M. Mann v. The University of Denver, and the instant case, counsel for Safeway has not been able to dedicate sufficient time to finalizing the brief. 3. Further, counsel is in the process of obtaining signatures on affidavits that

it intends to file with its brief in support of its motion for summary judgment. Because

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one of the witnesses who will sign such an affidavit was out of the office last week, counsel was not able to obtain his signature on the affidavit. As a result, Safeway respectfully requests a one- week extension of time to file its brief in support of its motion for summary judgment. 4. Pursuant to D.C.Colo.LCivR 6.1(d), a copy of this motion is being served

on Defendant. 5. Pursuant to D.C.Colo.LCivR 7.1, undersigned counsel conferred with

Plaintiff's counsel, Robert Truhlar, on July 25, 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 August 1, 2005 to submit its brief in support of its motion for summary judgment. Dated: July 25, 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.

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CERTIFICATE OF SERVICE

I hereby certify that on July 25, 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]

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04cv01214-PSF- 0ES KATHLEEN M. TOWERS, Plaintiff, vs. SAFEWAY INC. Defendant. ________________________________________________________________________ ORDER GRANTING MOTION FOR EXTENSION OF TIME TO FILE BRIEF IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT ________________________________________________________________________ THIS MATTER having come before the Court on Defendant Safeway Inc.'s ("Safeway")Unopposed Motion for Extension of Time to File Brief in Support of Motion for Summary Judgment, and the Court being fully advised, IT IS ORDERED THAT Defendant Safeway's Unopposed Motion for Extension of Time to File Brief in Support of Motion for Summary Judgment is granted. Safeway shall have to and including August 1, 2005 to file its Brief in Support of Motion for Summary Judgment. Date: July ___, 2005. BY THE COURT: __________________________________ United States District Court Judge

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