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

Case 1:04-cv-01072-ZLW-BNB

Document 95

Filed 09/15/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-CV-01072-ZLW-BNB JOHN E. LOPEZ, Applicant, v. CARL ZENON, and KEN SALAZAR, The Attorney General of the State of Colorado, Respondents.

UNOPPOSED MOTION FOR AN EXTENSION OF SIXTY (60) DAYS TO FILE APPLICANT'S TRAVERSE

COMES NOW John E. Lopez, Applicant in the above-styled action and hereinafter referred to as "Applicant," by and through undersigned counsel, and moves this Court to enter an order permitting the undersigned counsel sixty (60) days, up to and including November 13, 2006, to file his traverse in this case. In support of this motion, the Applicant states as follows: 1. The Respondents have filed their Amended Answer referencing several hundred pages of exhibits. A detailed response is required by the Applicant 2. In addition, undersigned counsel needs to review the contents of the Respondent's answer with the Applicant who has requested that he review the State's response and the traverse prior to its filing. 3. Undersigned counsel has contacted Ms. Hone, counsel for the respondents, who indicated that she has no objection to this motion.

Case 1:04-cv-01072-ZLW-BNB

Document 95

Filed 09/15/2006

Page 2 of 2

4. This Motion is made in good faith, and not for the purpose of delay. No prejudice could inure to any party as a result of the granting of this motion as the Applicant remains incarcerated serving a life sentence.

WHEREFORE, the Applicant respectfully requests that this Honorable Court grant his Motion to permit the undersigned counsel sixty (60) days, up to and including November 13, 2006, to file his traverse in this case.

DATED this 15 day of September, 2006.

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Respectfully submitted, s/Robert G. Levitt Robert G. Levitt, Esq. Counsel for Applicant Colorado Reg. 24252 600 17th Street Suite 2800 South Denver, Colorado 80202 (303) 377-9000

CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on this 15th day of September, 2006, I electronically filed the foregoing UNOPPOSED MOTION FOR AN EXTENSION OF SIXTY (60) DAYS TO FILE APPLICANT'S TRAVERSE with the Clerk of the Court using the ECF system which will send notification of such filing to the following e-mail address: [email protected] s/Robert G. Levitt Robert G. Levitt, Esq.

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