Free Motion for Leave to File Excess Pages - District Court of Colorado - Colorado

Case 1:04-cv-01135-REB-PAC

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Filed 06/21/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-CV-1135-REB-PAC ADRIAN OSORNIO, BETSY MARTINEZ, JESSICA WILLIAMS, ISTQUIA REYNA, MIGUEL FONTANET, and MAYRA CARMONA, Plaintiffs, v. T-MOBILE USA, INC., Defendant. UNOPPOSED MOTION FOR EXTENSION OF PAGE LIMITS FOR SUMMARY JUDGMENT REPLY BRIEF

Pursuant to REB Civ. Practice Standard V.H.3.a., defendant T-Mobile USA, Inc. ("T-Mobile") moves for the entry of an order extending the page limit for its summary judgment reply brief from 10 pages to 15 pages. A proposed order is attached hereto. As grounds for this motion, T-Mobile states as follows: 1. 2. 3. The above cited Practice Standard limits reply briefs to 10 pages. In this case, six plaintiffs have asserted claims against T-Mobile. One or more of the plaintiffs have asserted claims for race/national origin

discrimination, retaliation, breach of contract, promissory estoppel, and sexual harassment. Although there is some factual overlap, there are separate facts for each claim which must be presented and discussed.

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Case 1:04-cv-01135-REB-PAC

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4.

In many instances, the individual circumstances of the plaintiffs must be

described and analyzed. For example, the alleged adverse action by T-Mobile must be discussed for each of the five plaintiffs asserting Title VII retaliation claims. 5. As required by Local Rule 7.1A, David Hammond, counsel for T-Mobile,

conferred with counsel for the plaintiffs, Maria Lighthall, by telephone on June 10, 2005. During that conversation, Ms. Lighthall stated that the plaintiffs would have no objection to the granting of this motion.

Dated: June 21, 2005. s/ David R. Hammond David R. Hammond Elizabeth J. McNamee DAVIS GRAHAM & STUBBS LLP 1550 Seventeenth Street, Suite 500 Denver, CO 80202 Telephone: (303) 892-9400 E-mail: [email protected] [email protected] ATTORNEYS FOR DEFENDANT

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Case 1:04-cv-01135-REB-PAC

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CERTIFICATE OF SERVICE The undersigned hereby certifies that, on this 21st day of June 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: Lee T. Judd, Esq. Andrew T. Brake, P.C. 777 E. Girard Avenue, #200 Englewood, CO 80113-2767 [email protected] s/_David R. Hammond______________ David R. Hammond Elizabeth J. McNamee Attorneys for Defendant DAVIS GRAHAM & STUBBS LLP 1550 Seventeenth Street, Suite 500 Denver, CO 80202 Telephone: (303) 892-9400 Facsimile: (303) 893-1379 E-mail: [email protected] [email protected]