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

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

Document 72

Filed 01/13/2006

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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 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 30-day extension of time to respond to the multiple 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 objected to this extension of time request. 2. Plaintiff's counsel has been preparing for and will be in trial before Judge Krieger beginning January 23, 2006 for 2 weeks. While some progress has been

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

Document 72

Filed 01/13/2006

Page 2 of 3

made on the responses to the motions for summary judgment, because of plaintiff's counsel's schedule preparing for trial and attending trial, he will have insufficient time to respond to the motions within the timeframes originally set by the Court. 3. The responses are currently due January 17, 2006. WHEREFORE, plaintiffs respectfully request to and

including February 16, 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 January 10, 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 72

Filed 01/13/2006

Page 3 of 3

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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