Free Supplement/Amendment - District Court of Colorado - Colorado

Case 1:04-cv-00684-EWN-MEH

Document 92

Filed 03/02/2006

Page 1 of 3

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 04-cv-00684-EWN-MEH

JOSEPH STEINBACH, JR. Plaintiff, v. OMNI PROPERTIES, INC, Defendant.

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY BRIEF

Defendant Omni Properties, Inc. ("Omni"), requests an extension of time, through March 22, 2006, in which to file its reply brief in support of Omni's Motion for Summary Judgment. This motion is based on the following: 1. The parties are currently pursuing settlement negotiations through the Tenth Circuit Mediation Office toward a global settlement of Joseph and Jason Steinbach's claims against Omni, and a mediation date has been set before the Tenth Circuit mediator. 2. To facilitate ongoing settlement opportunities, the Tenth Circuit is extending the due date for Jason Steinbach's opening brief, for a second time, beyond the current March 6, 2006 deadline. 3. To further facilitate settlement opportunities, Omni requests an extension of time, through March 22, 2006, in which to file its reply brief in support of Omni's Motion for Summary Judgment. 4. Omni's reply brief is currently due March 6, 2006.

5. As the requested extension will further settlement opportunities, no party will be prejudiced by the extension. 6. Counsel for Joseph Steinbach, Patricia S. Bangert, has authorized counsel undersigned to advise the court that she has no objection to the requested extension.

Case 1:04-cv-00684-EWN-MEH

Document 92

Filed 03/02/2006

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Dated: March 2, 2006. Respectfully submitted,

s/Colleen M. Rea Colleen M. Rea, Esq. #024960 FORD & HARRISON LLP 1675 Broadway, Suite 2150 Denver, CO 80202 Telephone: (303) 592-8860 Facsimile: (303) 592-8861 E-mail: [email protected] ATTORNEYS FOR DEFENDANT OMNI PROPERTIES, INC.

Case 1:04-cv-00684-EWN-MEH

Document 92

Filed 03/02/2006

Page 3 of 3

CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on March 2, 2006, I electronically filed the foregoing using the UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY BRIEF CM/ECF system, which will send notification of such filing to the following e-mail addressee: Patricia S. Bangert, Esq. [email protected] Also e-mailed to Patricia S. Bangert, Esq. at: [email protected]

s/Colleen M. Rea Colleen M. Rea, Esq. #024960 FORD & HARRISON LLP 1675 Broadway, Suite 2150 Denver, CO 80202 Telephone: (303) 592-8860 Facsimile: (303) 592-8861 [email protected] E-mail:
Denver:10955.1