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

Case 1:04-cv-01124-JLK-MEH

Document 98

Filed 04/19/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. O4-MSK-1124(OES) LINDA FORGACS, MONICA JONES, DANIEL LINK, GRACE MORENO AND PAM ROGGE, Plaintiffs, V. EYE CARE CENTER OF NORTHERN COLORADO; WILLIAM L. BENEDICT, M.D.; JOEL S. MEYERS, M.D.; MORRIS TILDEN, M.D.; IRENE OLIJNYK, M.D.; and JAY R. HOLMS, Defendants. ___________________________________________________________________ MOTION FOR EXTENSION OF TIME TO FILE SUPPLEMENTAL FILING IN RESPONSE TO ORDER OF APRIL 11, 2006 _________________________________________________________________ Come now the Plaintiffs, by and through counsel, and

respectfully requests that this Court grant an extension of time to file their supplemental filings as requested by this Court. As grounds for the motion, plaintiffs' counsel states as follows:

1.

Pursuant to Local Rule 7.1, plaintiffs' counsel conferred with defendants' counsel prior to filing this motion. Defendants' counsel indicated that he objects to the herein request.

2.

Counsel for Plaintiff has been representing clients in a series of depositions for the majority of the

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Case 1:04-cv-01124-JLK-MEH

Document 98

Filed 04/19/2006

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week of April 17, 2006 in another Federal Court matter and preparing for said depositions during the week before and has not been able to complete the supplement.

3.

Additionally, Plaintiff's counsel has just recently received a supplement filed by Defendant and has not yet been able to review this with his clients, which he will do this weekend. Plaintiffs would

like to be able to address Defendant's supplemental information in the supplemental filing due.

4.

Counsel

for

the

Plaintiffs

plans

to

meet

with

Plaintiffs this weekend to continue discussions about possible resolutions of the case

5.

The supplemental filing is currently due April 19, 2006. Plaintiff's counsel requests an extension to and including Monday, April 24, 2006.

WHEREFORE,

plaintiffs

respectfully

request

to

and

including April 24, 2006 to complete the responses. Respectfully submitted,

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Case 1:04-cv-01124-JLK-MEH

Document 98

Filed 04/19/2006

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s/George C. Price George C. Price Attorney for Plaintiff 900 Logan Street Denver, CO 80203 Telephone:(303)861-5500 [email protected]

CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on April 19, 2006, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail address: John R. Paddock, Jr. Pryor Johnson Carney Karr Nixon, P.C. 5619 DTC Parkway, Suite 1200 Greenwood Village, CO 80111-3061 [email protected]

s/George C. Price George C. Price Attorney for Plaintiff 900 Logan Street Denver, CO 80203 Telephone:(303)861-5500 Facsimile: (303) 484-2421 [email protected]

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