Free Motion to Reset - District Court of Colorado - Colorado

Case 1:04-cv-00687-PSF-BNB

Document 110

Filed 08/09/2006

Page 1 of 3

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-00687-PSF-BNB MARY JO LAIRD, Plaintiff, v. GUNNISON COUNTY, a County of the State of Colorado, acting through THE BOARD OF COUNTY COMMISSIONERS OF THE COUNTY OF GUNNISON, THE BOARD OF TRUSTEES FOR THE GUNNISON COUNTY PUBLIC LIBRARY, and JOHN DEVORE and PEGGY MARTIN, in their individual capacities, Defendants.

UNOPPOSED MOTION TO CONTINUE FINAL TRIAL PREPARATION CONFERENCE AND TO ALLOW LEAD COUNSEL TO APPEAR BY TELEPHONE

Plaintiff, by undersigned counsel hereby moves to continue the Final Trial Preparation Conference (Document 108) to Monday, November 20, 2006 at 9:30 a.m., and further moves for leave of lead counsel to appear by telephone, with associate counsel, Stuart Jay, appearing in person. As grounds therefor Plaintiff states as follows: Pursuant to D.C. Colo. LCivR 7.1A, Nathan Davidovich certifies that he has conferred with Defendants' attorney, Eric M. Ziporin, regarding this Motion, and he does not oppose this Motion. 1. Nathan Davidovich, Lead counsel in this matter, will be in Israel on the presently

scheduled date of November 17th, in order to be able to celebrate Thanksgiving with his family in Israel. If he were to be present in Denver on that date, he would be unable to return to Israel for Thanksgiving and then return again to Denver less than a week later.

Case 1:04-cv-00687-PSF-BNB

Document 110

Filed 08/09/2006

Page 2 of 3

2.

Nathan Davidovich is unable to appear by telephone on the presently scheduled

date as it is a Friday, and because of the time difference between Denver and Israel, it would already be the Sabbath at the time of the conference and Nathan Davidovich would be unable to participate. Nathan Davidovich will be able to participate by telephone at a rescheduled conference held on November 20, 2006 and associate counsel Stuart Jay will be able to appear in person at that time. Dated this 9th day of August, 2006. Respectfully submitted, KENNEDY CHILDS & FOGG, P.C.

s/ Nathan Davidovich Nathan Davidovich Ronald H. Nemirow Stuart A. Jay 1050 Seventeenth Street, Suite 1050 Denver, Colorado 80265 (303) 825-2700 (303) 825-0434 [email protected] ATTORNEYS FOR PLAINTIFF

Case 1:04-cv-00687-PSF-BNB

Document 110

Filed 08/09/2006

Page 3 of 3

CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on August 9, 2006, I filed the foregoing UNOPPOSED MOTION TO CONTINUE FINAL TRIAL PREPARATION CONFERENCE AND TO ALLOW LEAD COUNSEL TO APPEAR BY TELEPHONE with the United States District Court for the District of Colorado via the CM/ECF System which will send notification to following individuals: Eric M. Ziporin, Esq. Senter Goldfarb & Rice 1700 Broadway, Suite 1700 Denver, Colorado 80290

/s/ Julie Rotenberg Julie Rotenberg