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

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

Document 80

Filed 02/21/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. O4-CV-01124-JLK-MEH 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. ___________________________________________________________________ UNOPPOSED MOTION FOR AN ADDITIONAL EXTENSION OF TIME TO RESPOND TO THE MOTIONS FOR SUMMARY JUDGMENT FILED BY THE DEFENDANTS IN THIS MATTER _________________________________________________________________ Come now the plaintiffs, by and through counsel, and

respectfully request that this Court grant an extension of time to respond to the motions for summary judgment filed by the defendants in this matter. 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 has no objection to this extension of time request. 2. Plaintiff's counsel originally requested an extension because he was preparing for and trying a case before Judge Krieger that began on January 23, 2006 and ran for 1

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

Document 80

Filed 02/21/2006

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almost 2 weeks. Subsequent to the conclusion of the trial, Plaintiffs' counsel became ill with the flu. An additional extension was requested and granted. It

appears that counsel was a bit too optimistic about his recovery and needs additional time to respond. 3. The response is currently due an February 21, to 2006. and

Plaintiff's

counsel

requests

extension

including February 24, 2006. WHEREFORE, plaintiffs respectfully request to and

including February 24, 2006 to complete the responses. Respectfully submitted, 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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Case 1:04-cv-01124-JLK-MEH

Document 80

Filed 02/21/2006

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CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on February 21, 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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