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

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

Document 65

Filed 08/05/2005

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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. ______________________________________________________________________________ PLAINTIFF'S UNOPPOSED MOTION FOR TWO WEEK EXTENSION OF DEADLINES RELATING TO EXPERT DISCLOSURES AND EXPERT DISCOVERY ______________________________________________________________________________ Plaintiff, by and through her attorneys, Dietze and Davis, P.C., respectfully moves this Court to extend the deadlines relating to expert disclosures and expert discovery by two weeks each. As grounds for her motion, Plaintiff states: 1. At a hearing on April 14, 2005, the Magistrate Judge set the following deadlines

relating to expert disclosures and expert discovery: a. b. c. Affirmative expert disclosures: Rebuttal expert disclosures: Expert discovery: August 15, 2005 October 3, 2005 October 17, 2005

These deadlines are reflected in the Court's Minute Order of April 18, 2005. 2. The undersigned counsel for Plaintiff will be on vacation the weeks of August 8

and 15, 2005. He has been in discussions with Plaintiff's expert with regard to the preparation

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

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of a report to be filed with Plaintiff's expert disclosure. However, counsel's vacation prevents the finalization of that report and the filing of Plaintiff's expert disclosure by August 15, 2005. 3. The undersigned will be returning to the office on August 22, 2005. Plaintiff

requests that the deadline for affirmative expert disclosures be extended by two weeks, until August 29, 2005. This will give the undersigned one week after his return to file the disclosure. Plaintiff proposes that the deadlines for rebuttal disclosures and for expert discovery also be extended by two weeks, to October 17 and October 31, respectively, so that Defendants are not prejudiced by this extension and the parties have adequate time to conduct expert discovery. 4. 5. This matter is not set for trial until May 22, 2006. Pursuant to Local Rule 7.1, counsel for Plaintiff has conferred with Counsel for

Defendants on the substance of this motion. Counsel for Defendants have informed the undersigned that they do not object to the requested extensions of time. 6. Justice requires that the requested extensions be granted.

WHEREFORE, Plaintiff respectfully requests that this Court extend the deadline for affirmative expert disclosures to August 29, 2005, the deadline for rebuttal expert disclosures to October 17, 2005, and the deadline for expert discovery to October 31, 2005. Plaintiff requests such other and further relief as the Court deems just and proper. Dated this 5th day of August, 2005.

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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 CERTIFICATE OF SERVICE I hereby certify that on August 5, 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/ 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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