Free Response to Motion - District Court of Colorado - Colorado

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

Document 74

Filed 01/13/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-CV-1124-JLK-OES LINDA FORGACS, et al., Plaintiffs, vs. EYE CARE CENTER OF NORTHERN COLORADO, P.C. et al., Defendants.

DEFENDANTS' STIPULATION TO PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO RESPOND TO MOTIONS FOR SUMMARY JUDGMENT

Defendants, through counsel, file their Stipulation to Plaintiff's Motion for Extension of Time to Respond to Motions for Summary Judgment. 1. On May 10, 2005, the Court entered Stipulated Scheduling Order which identified

December 14, 2005 as the Dispositive Motions Deadline. 2. Judgment. 3. The Minute Order on December 12, 2005 gave Plaintiffs until January 6, 2006 to Between December 9 and 14, 2005, Defendants filed their Motions for Summary

respond, and the Minute Order on December 14, 2005 gave Plaintiffs ten more days, until January 17, 2006 to respond. 4. Defendants initially objected to giving Plaintiffs a 30-day extension because

counsel for Plaintiffs knew well before December that dispositive motions would be filed in this

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

Document 74

Filed 01/13/2006

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case in early December to which responses would be due in early January and that his other case would be going to trial starting January 23. 5. Nevertheless, the pending motions address all the claims and, therefore, in

addition to extending professional courtesy to Plaintiffs' counsel, Defendants want to be sure that Plaintiffs will have no reason to assert that they did not have a full and fair opportunity to present any issue why their claims should not be dismissed on summary judgment. Wherefore, Defendants agree that Plaintiffs may have thirty more days, or until February 16, 2006 to respond to the summary judgment motions. Dated: January 13, 2006. Respectfully submitted,

By:

s/ John R. Paddock, Jr. John R. Paddock, Jr.

Attorney for Defendants CERTIFICATE OF SERVICE I certify that on this 13th day of January, 2006, a copy of the foregoing Defendants' Stipulation to Plaintiff's Motion for Extension of Time to Respond to Motions for Summary Judgment was served by ECF filing on the following: George Price, Esq. 1115 Grant Street, Suite 106 Denver, CO 80203 Fax: 303-484-2421
00278942.WPD; January 13, 2006 (5:21pm)

s/ Mary E. McNichols __________________________________

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