Free Motion for Extension of Time to File Response/Reply - District Court of Colorado - Colorado

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

Document 122

Filed 10/24/2006

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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 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 conferred with opposing counsel's office prior to filing this motion. Mr. Paddock is out of the country, but his legal assistant conferred with another shareholder of the firm who indicated that that there was no objection to this request. 2. Plaintiff's counsel is requesting this extension

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

Document 122

Filed 10/24/2006

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because of a medical problem that has arisen and that has and will require him to be out of the office part of last week and for significant

periods of time this week. 3. Plaintiff's counsel requests an extension to and including October 30, 2006. 4. Counsel is filing this motion on October 24, 2006 because of problems with the Adobe program which precluded conversion of the document to PDF format. WHEREFORE, plaintiffs respectfully request to and

including October 30, 2006 to complete 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] CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on Ocober 23, 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 2

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

Document 122

Filed 10/24/2006

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[email protected]

s/George C. Price George C. Price

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