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

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

Document 77

Filed 02/16/2006

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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 AN ADDIOTIONAL EXTENSION OF TIME TO RESPOND TO THE MOTIONS FOR SUMMARY JUDGMENT FILED BY THE DEFENDANTS IN THIS MATTER _________________________________________________________________ Come now the plaintiff by and through counsel and respectfully requests that this Court grant a 5-day 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, 1

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

Document 77

Filed 02/16/2006

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2006 and ran for almost 2 weeks. Subsequent to the conclusion of the trial, Plaintiffs' counsel became ill with the flu and has been unable to work for most of the last week and one-half 3. The responses are currently due February 16, 2006. Plaintiff's counsel requests an extension to and including February 21, 2006. WHEREFORE, plaintiffs respectfully request to and

including February 21, 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] CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on February 16, 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]

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

Document 77

Filed 02/16/2006

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

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