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

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

Document 126

Filed 10/30/2006

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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 AN ADDITIONAL EXTENSION OF TIME TO RESPOND TO THE MOTION FOR SANCTIONS _________________________________________________________________ Come now the plaintiffs, by and through counsel, and

respectfully requests that this Court grant a 7-day extension of time to respond to the motion for sanctions 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 placed a telephone call to Defendants' counsel on the morning of October 30, 2006 to confer about this extension request and to determine counsel's availability for a settlement conference. As of the time of the filing of this motion, there had been no return call or message from Defendants' counsel.

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

Document 126

Filed 10/30/2006

Page 2 of 3

2.

Plaintiff's counsel is requesting this extension because of a medical problem that has arisen and that has required him to be out of the office for significant periods of time over the past two

weeks. It is anticipated that he will be out for part of this week as well. 3. Plaintiff's counsel has attempted to set up a

settlement conference at which the remaining issues in the case can hopefully be resolved. Counsel has cleared Monday, November 6, 2006 at 4:00 p.m. with the Court and is waiting to hear back from

Defendants' counsel about his availability. 4. Plaintiff's counsel requests an extension to and including November 8, 2006. WHEREFORE, plaintiff respectfully requests to and

including October 30, 2006 to file the response. 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]

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

Document 126

Filed 10/30/2006

Page 3 of 3

CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on October 30, 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]

s/George C. Price George C. Price

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