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

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

Document 34

Filed 07/11/2005

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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 AN ADDITIONAL EXTENSION OF TIME TO RESPOND TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT ________________________________________________________________________

COME NOW the Plaintiffs, by and through their counsel, George C. Price, and hereby request that this Court grant an additional extension of time to respond to Defendants' Motion for Summary Judgment. Counsel for the Plaintiffs, pursuant to Local Rule 7.1, has conferred with the office of Defendants' counsel and has been informed that Mr. Paddock has no objection to this request. The response is currently due on July 11, 2005. Counsel for the Plaintiffs makes this request for two reasons. First, counsel is attempting to obtain documents that he believes may be necessary to the resolution of the summary judgment motion that normally would have been sought in the discovery process. Second, counsel for the Plaintiffs injured his shoulder over the weekend. This problem has made work a little more difficult and writing a problem. Counsel requests an additional week, to and including July 18, 2005 to complete and file the response to Defendants' Motion for Summary Judgment Respectfully submitted this 11th day of July, 2005.

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

Document 34

Filed 07/11/2005

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, to:

John R. Paddock, Esq. Pryor, Johnson, Carney, Montoya and Karr 5619 DTC Parkway, Suite 1200 Greenwood Village, CO 80111

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