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

Case 1:04-cv-01160-LTB-CBS

Document 71

Filed 09/28/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-01160-LTB-CBS ISABELLE DerKEVORKIAN, Plaintiff, v. LIONBRIDGE TECHNOLOGIES, INC., d/b/a LIONBRIDGE US, INC., SHARRYN E. ROSS and ROSS, MARTEL & SILVERMAN, LLP Defendants. ______________________________________________________________________________ UNOPPOSED MOTION FOR EXTENSION OF TIME ______________________________________________________________________________ Plaintiff, by and through her attorneys, Dietze and Davis, P.C., respectfully moves this Court for its order extending the time for the filing of her response brief to Defendants Sharryn E. Ross and Ross, Martel & Silverman, LLP's Motion for Summary Judgment by seven days, to and including October 10, 2005. As grounds for her motion, Plaintiff states: 1. The Ross Defendants filed their Motion for Summary Judgment on September 12,

2005. Pursuant to Local Rule 56.1(A), Plaintiff's response presently is due on October 3, 2005. 2. The Ross Defendants' Motion for Summary Judgment contains numerous arguments

and references several different attachments. The undersigned counsel for Plaintiff needs and requests an additional seven days, to and including October 3, 2005, to file the Response Brief. 3. 4. Trial is scheduled to commence October 2, 2006. Pursuant to Local Rule 7.1, counsel for Plaintiff certifies that he has communicated

with counsel for the Ross Defendants and counsel for Defendant Lionbridge and that neither object

Case 1:04-cv-01160-LTB-CBS

Document 71

Filed 09/28/2005

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to the requested extension. WHEREFORE, Plaintiff respectfully prays for this Court's order extending the time within which she may file her response brief to the Ross Defendants' Motion for Summary Judgment to and including October 10, 2005. Dated this 28th day of September, 2005. Respectfully submitted, DIETZE and DAVIS, P.C. By: "s/ Joel C. Maguire" Joel C. Maguire Dietze and Davis, P.C. 2060 Broadway, Suite 400 Boulder, CO 80302 Telephone: (303) 447-1375 Fax: (303) 440-9036 Email: [email protected] Attorney for Plaintiff Isabelle DerKevorkian

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Case 1:04-cv-01160-LTB-CBS

Document 71

Filed 09/28/2005

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CERTIFICATE OF SERVICE I hereby certify that on September 28, 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 e-mail addresses: John Edwin Bolmer, II [email protected] [email protected] Dan S. Cross [email protected] [email protected] David Everett Leavenworth, Jr. [email protected] [email protected] [email protected] By: "s/ Susan J. Armour" Susan J. Armour, Legal Assistant Dietze and Davis, P.C. 2060 Broadway, Suite 400 Boulder, CO 80302 Telephone: (303) 447-1375 Fax: (303) 440-9036 Email: [email protected]

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