Free Motion to Amend/Correct/Modify - District Court of Colorado - Colorado

Case 1:04-cv-01109-WDM-PAC

Document 108

Filed 10/12/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-1109-WDM-PAC MARK A. JOHNS and LISA JOHNS Plaintiffs, vs. GENIE INDUSTRIES, INC., n/k/a TEREX CORPORATION, a foreign corporation; UNITED RENTALS, INC., a foreign corporation,; THE BOSCH GROUP, a/k/a ROBERT BOSCH CORPORATION; KELCH CORPORATION; and BONAR PLASTICS, INC. Defendants. ______________________________________________________________________________ THIRD STIPULATED MOTION TO AMEND THE SCHEDULING ORDER ______________________________________________________________________________ COMES NOW all parties, by and through their respective counsel and hereby jointly pursuant to D.C. COLO.L.CivR. 7.1 move this Honorable Court to amend the current scheduling order pursuant to as described herein. AS GROUNDS for this joint motion, the parties state as follows: 1. 2. Plaintiffs' expert witness designations are due on Monday, October 18, 2005. Over the past 10 days, Plaintiffs' counsel, William L. Keating has been required to devote a good deal of time to serious medical matters involving a parent. These medical matters have included hospice placement as well as arranging other family matters. 3. As a result of these family commitments, Plaintiffs' counsel has not been able to complete the necessary meetings and conferences with experts whose designations are due. 4. Plaintiffs' counsel has discussed this issue with all defense counsel and all

Case 1:04-cv-01109-WDM-PAC

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counsel have stipulated and agreed to the filing of this Motion to Amend the Scheduling Order. 5. The parties request that the Court modify the current scheduling order as follows: Plaintiffs shall provide all Rule 26(a)(2) information by October 31, 2005. Defendants shall provide all Rule 26(a)(2) information by November 31, 2005. Plaintiffs rebuttal expert Rule 26(a)(2) information shall be provided December 15, 2005. All experts shall be deposed by January 27, 2006. All written discovery shall be served by December 15, 2005. The discovery cut-off is extended to January 27, 2006. The dispositive motions deadline is extended to February 17, 2006. This amended scheduling order will permit Plaintiffs' counsel the time necessary to complete all family medical matters and to complete the expert witness designations.

Case 1:04-cv-01109-WDM-PAC

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Case 1:04-cv-01109-WDM-PAC

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Case 1:04-cv-01109-WDM-PAC

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Case 1:04-cv-01109-WDM-PAC

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Case 1:04-cv-01109-WDM-PAC

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