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

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

Document 32

Filed 06/23/2005

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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 RESPOND TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT ________________________________________________________________________

COME NOW the Plaintiffs, by and through their counsel, George C. Price, and hereby requests that this Court grant an extension of time to respond to Defendants' Motion for Summary Judgment. 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 has no objection to this request. The response is currently due on June 27, 2005. Counsel for the plaintiff makes this request because of an unusually busy schedule. In the past twenty days, counsel has been involved in two full day depositions, the drafting of a summary judgment response, preparation for and attendance at two settlement conferences and three scheduling conferences, three trials, and the preparation of an appeal brief. Counsel requests an additional two weeks, to and including July 11, 2005 to complete and file the response to Defendants' Motion for Summary Judgment Respectfully submitted this 23rd day of June, 2005.

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

Document 32

Filed 06/23/2005

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. Hale Friesen, LLP 1430 Wynkoop #300 Denver, CO 80202

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