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

Case 1:04-cv-01149-RPM

Document 49

Filed 07/19/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No.: 04-cv-1149-RPM-MJW MICHAEL ANDREW DARR, Plaintiff, v. ROBERT NEWMYER; OUTLAW PRODUCTIONS, INC., a California corporation; TOWN OF TELLURIDE, COLORADO, Defendants.

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY BRIEF IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT

CERTIFICATION Pursuant to D.C.COLO.LCivR 7.1(A), Allyson Hodges has advised the undersigned that she has conferred with counsel for Plaintiff who does not object to this motion. Defendant, Town of Telluride, appearing separately from the other Defendant herein, by and through its attorneys, Nathan, Bremer, Dumm & Myers, P.C., hereby submits its Unopposed Motion for Extension of Time to File Reply Brief in Support of Motion for Summary Judgment, and as grounds therefore, this Defendant states and shows unto the Court as follows: 1. Defendant, Town of Telluride, filed a Motion for Summary Judgment and

Supporting Brief on May 31, 2005. 2. Plaintiff's counsel requested and undersigned counsel consented to an extension

of time for Plaintiff to file his Response Brief. As part of their duty to confer, Defendant's

Case 1:04-cv-01149-RPM

Document 49

Filed 07/19/2005

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counsel also asked Plaintiff's attorney to agree to an extension of time up to and including August 5, 2005, within which to file this Defendant's Reply Brief. 3. As grounds for their request for an extension to file their Reply Brief, the

undersigned counsel notes that Allyson Hodges had previously planned a family vacation for two weeks, and based on the Plaintiff's new response deadline, the Reply would come during her vacation. Accordingly, Plaintiff's counsel agreed to extend the Reply date to August 5, 2005. 4. request. 5. 6. No prior extensions have been requested for this Reply Brief. A copy of this motion has been sent to the Town of Telluride c/o its Town There is no trial date in this case and none of the parties will be prejudiced by this

Attorney, Susan Baker. WHEREFORE, Defendant, Town of Telluride, respectfully requests that it be granted an extension of time within which to file its Reply Brief in Support of Summary Judgment up to and including Friday, August 5, 2005. Respectfully submitted, NATHAN, BREMER, DUMM & MYERS, P.C.

s/ J. Andrew Nathan J. Andrew Nathan Allyson C. Hodges Attorneys for Defendant Nathan, Bremer, Dumm & Myers, P.C. 3900 E. Mexico Avenue, Suite 1000 Denver, CO 80210 (303) 691-3737 (303) 757-5106 E-mails: [email protected]; [email protected]

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Case 1:04-cv-01149-RPM

Document 49

Filed 07/19/2005

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CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on July 19, 2005 , I electronically filed the foregoing Unopposed Motion for Extension of Time to file Reply Brief in Support of Motion for Summary Judgment with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail address: Angela Ekker, Esq. E-mail: [email protected] John H. Steel, Esq. E-mail: [email protected] Gary L. Doehling, Esq. E-mail: [email protected] Daniel Grossman, Esq. E-mail: [email protected] Susan Baker, Esq. E-mail: [email protected]

s/ J. Andrew Nathan J. Andrew Nathan Allyson C. Hodges Attorneys for Defendant Nathan, Bremer, Dumm & Myers, P.C. 3900 E. Mexico Avenue, Suite 1000 Denver, CO 80210 (303) 691-3737 (303) 757-5106 E-mails: [email protected]; [email protected]

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