Free Motion for Leave to File Excess Pages - District Court of Colorado - Colorado

Case 1:04-cv-01067-MSK-CBS

Document 102

Filed 05/02/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-1067-REB-CBS WILLIAM R. CADORNA, Plaintiff, v. CITY AND COUNTY OF DENVER, COLORADO, a municipal corporation, Defendant. DEFENDANT'S UNOPPOSED MOTION FOR LEAVE TO EXCEED THE TEN PAGE LIMIT FOR RELY BRIEF IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT

Defendant, City and County of Denver ("Denver"), by undersigned counsel, respectfully requests leave to file its Reply Brief in Support of Motion for Summary Judgment exceeding the Court's ten (10) page limit for such briefs by one page which contains only the signature block. AS GROUNDS THEREFORE, Denver states as follows: D.C.COLO.LCivR 7.1 Certification 1. As required by D.C.COLO.LCivR 7.1, the Defendant has contacted

Plaintiff's counsel concerning this motion who advises that he has no objection to this motion.

Case 1:04-cv-01067-MSK-CBS

Document 102

Filed 05/02/2006

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2.

Denver is filing with this motion its Reply Brief in Support of Motion for

Summary Judgment. 4. The Practices Standards for this Court limit the number of pages for reply

briefs to ten (10) pages including, among other things, the signature block. See REB Civ. Practice Standard V.H.3 (a). 5. Denver's reply brief excluding the signature block is ten (10) pages with

only the signature block on the eleventh page. 7. Denver does not believe that the Plaintiff or the Court will be prejudiced if

this motion is granted as the heading, argument and closing are all contained in ten (10) pages. WHEREFORE, Defendant respectfully requests the entry of an Order permitting it to submit its Reply Brief in Support of Motion for Summary Judgment that is in excess of ten (10) pages where only the signature block appears on the eleventh page. Respectfully submitted this 2nd day of May, 2006. Jack M. Wesoky Assistant City Attorney s/ Jack M. Wesoky Jack M. Wesoky Assistant City Attorney Denver City Attorney's Office 201 W. Colfax Ave., Dept. 1108 Denver, CO 80202-5332 Telephone: 720-913-3100 Fax: 720-913-3190 E-Mail: [email protected] Attorney for Defendant City and County of Denver

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Case 1:04-cv-01067-MSK-CBS

Document 102

Filed 05/02/2006

Page 3 of 3

CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on May 2, 2006, I electronically filed the foregoing DEFENDANT'S UNOPPOSSED MOTION FOR LEAVE TO EXCEED THE TEN PAGE LIMIT FOR THE REPLY BRIEF IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Mark E. Brennan [email protected] and I hereby certify that I have mailed the document to the following non CM/ECF participants in the manner indicated by the non-participant's name: Interoffice mail to: Manager Alvin LaCabe, Jr. Manager of Safety Department of Safety 1331 Cherokee St. Denver, CO 80204 Chief Larry Trujillo Department of Safety Denver Fire Department 745 W. Colfax Denver, CO 80204

s/ Marilyn Barela Marilyn Barela, Legal Secretary Office of the Denver City Attorney

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