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

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

Document 48

Filed 10/12/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 04-K-1124 (OES) LINDA FORGACS, MONICA JONES, DANIEL LINK, GRACE MORENO and PAM ROGGE, Plaintiffs, vs. EYE CARE CENTER OF NORTHERN COLORADO; WILLIAM L. BENEDICT, M.D.; JOEL S. MEYERS, M.D.; MORRIS TILDEN, M.D.; IRENE OLIJYNK, M.D.; and JAY R. HOLMS, Defendants. ________________________________________________________________________ UNOPPOSED MOTION FOR EXTENSION OF TIME TO PROPOUND DISCOVERY REQUESTS ________________________________________________________________________

COME NOW the Plaintiffs, by and through their counsel, George C. Price, and hereby request that this Court grant an extension of time to propound discovery requests in this case. Counsel for the Plaintiff, pursuant to Local Rule 7.1, has conferred with the office of Defendants' counsel and has been informed that Mr. Paddock is on jury duty and is not in the office. His paralegal has indicated that Mr. Paddock would likely not have an objection. The requests are currently due to be propounded on October 12, 2005. Counsel for the Plaintiffs injured his back on the evening of October 11, 2005 while clearing a tree that was destroyed in the recent snowstorm. This injury is making it impossible to complete any work. Counsel requests an additional five days, to and including October 17, 2005 to propound the discovery requests. Respectfully submitted this 12th day of October, 2005.

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

Document 48

Filed 10/12/2005

Page 2 of 2

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

CERTIFICATE OF MAILING I certify that on June 23, 2005, I sent a true and correct copy of Plaintiff's Motion for Extension of Time to Respond to Defendants' Motion for Summary Judgment, by US Mail and electronic filing, to:

John R. Paddock, Esq. Pryor Johnson Carney Karr Nixon 5619 DTC Parkway Greenwood Village, CO 80111 s/ George C. Price__________

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