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

Case 1:04-cv-01146-LTB-CBS

Document 78

Filed 03/21/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-1146-LTB-CBS GARY S. COHEN, Plaintiff, v. INFOLINK SCREENING SERVICES, INC., a California corporation; and PHOENIX RESEARCH, INC., an Ohio corporation, Defendants.

DEFENDANT INFOLINK SCREENING SERVICES, INC'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE STIPULATION TO DISMISS

Defendant Infolink Screening Services, Inc. ("Infolink"), by and through its attorney, C. Todd Drake, moves this honorable Court for a one-week extension of time in which to file an executed Stipulation to Dismiss Plaintiff's claims, through and including March 31, 2006, AND AS GROUNDS THEREFOR, state as follows: 1. Pursuant to D.C.COLO.LCivR. 7.1, the undersigned counsel has conferred

with Plaintiff's counsel prior to filing this motion and Plaintiff's counsel agreed to the relief sought in this motion. 2. A settlement conference was held in this matter on March 10, 2006, at

which time Plaintiff and Infolink reached a settlement of Plaintiff's claims. 3. Pursuant to the Court's March 13, 2006 Amended Minute Order, a

stipulation or motion to dismiss with prejudice, pursuant to Fed.R.Civ.P. 41(a), must be filed on or before March 24, 2006.

Case 1:04-cv-01146-LTB-CBS

Document 78

Filed 03/21/2006

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4.

The appropriate settlement documents have been prepared and are in the

process of being finalized and executed. However, finalizing the settlement and filing a Stipulated Dismissal by March 24, 2006 may not be possible. Infolink therefore requests a one-week extension of time to file the Stipulated Dismissal. 5. Neither the parties nor the Court will be prejudiced by this requested brief

extension of time. WHEREFORE, Infolink respectfully requests that the Court enter an Order extending the time in which to file an executed Stipulation to Dismiss Plaintiff's claims, through and including March 31, 2006, DATED this 21st day of March, 2006. Respectfully submitted, TIEMEIER & HENSEN, P.C.

s/ Stephen J. Hensen_______________ C. Todd Drake Stephen J. Hensen 1515 Arapahoe Street, Suite 1300 Denver CO 80202 Telephone: 303-572-1515 Attorneys for Defendant Infolink Screening Services, Inc.

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Case 1:04-cv-01146-LTB-CBS

Document 78

Filed 03/21/2006

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CERTIFICATE OF SERVICE The undersigned hereby certifies that on the 21st day of March, 2006, a true and correct copy of the foregoing was filed and served via PACER electronic filing upon the below-noted individuals: Marc F. Bendinelli, Esq. Joseph Lapham III, Esq. Bendinelli Law Office, P.C. 11184 Huron Street, Suite 10 Denver, Colorado 80234 Ashley Krause, Esq. Snell & Wilmer L.L.P. 1200 Seventeenth Street, Suite 1900 Tabor Center Denver, CO 80202 Matthew Buck, Esq. Keating Muething & Klekamp, PLL 1 East 4th Street, Suite 1400 Cincinnati, Ohio 45202

s/ Michael Jensen

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