Free Motion to Vacate - District Court of Colorado - Colorado

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

Document 68

Filed 08/18/2005

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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. ______________________________________________________________________________ MOTION (UNOPPOSED) OF PLAINTIFF TO VACATE AND RESET TRIAL DATE ______________________________________________________________________________ Plaintiff, by and through her attorneys, Dietze and Davis, P.C., respectfully moves this Court for its Order rescheduling the trial of this matter. As grounds for her motion, Plaintiff states: 1. Pursuant to Local Rule 7.1, the undersigned has conferred with Dan S. Cross, counsel

for Defendant Lionbridge Technologies, Inc., and with John E. Bolmer, II, counsel for Defendants Sharryn E. Ross and Ross, Martel & Silverman, LLP. Both have indicated that they have no objection to this Motion. 2. A five day jury trial is currently scheduled in this matter to commence on May 22,

2006. The Final Pre-Trial Conference is scheduled for April 26, 2006 at 8:00 o'clock a.m. 3. Counsel for Plaintiff has a conflict on the May 22, 2006 date, in that his son's college

graduation is scheduled for the same date. 4. Pursuant to a telephone conversation with this Division's Courtroom Deputy, the

undersigned has been advised that October 2, 2006 and October 16, 2006 are available for rescheduling the trial of this matter.

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

Document 68

Filed 08/18/2005

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5.

Plaintiff requests that the five day jury trial currently scheduled for May 22, 2006 be

rescheduled for October 2, 2006. In the alternative, Plaintiff respectfully requests that the trial be rescheduled for October 16, 2006. These dates have been cleared on all parties' calendars. WHEREFORE, Plaintiff respectfully requests that this Court enter an Order vacating and resetting the May 22, 2006 trial date to October 2, 2006, for a five day jury trial. Plaintiff requests such other and further relief as the Court deems just and proper. Dated this 18th day of August, 2005. Respectfully submitted, DIETZE and DAVIS, P.C. By: "s/ David J. Thrower" (for 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 68

Filed 08/18/2005

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CERTIFICATE OF SERVICE I hereby certify that on August 18, 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 email 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/ David J. Thrower" (for 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]

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