Free Motion for Extension of Time to File Response/Reply - District Court of Colorado - Colorado

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

Document 91

Filed 03/02/2006

Page 1 of 1

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.