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

Case 1:04-cv-00680-REB-CBS

Document 31

Filed 05/22/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. No. 04-cv-00680-REB-CBS DONALD KELLER, Plaintiff, v. QWEST COMMUNICATIONS INTERNATIONAL INC., QWEST ASSET MANAGEMENT COMPANY AND JOHN DOES 1-15, Defendants.

UNOPPOSED AND STIPULATED MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO WRITTEN DISCOVERY Pursuant to Federal Rule of Civil Procedure 6(b)(1), defendants Qwest Communications International Inc. and Qwest Asset Management Company (collectively "Defendants") submit this unopposed and stipulated motion for enlargement of time to respond to written discovery (this "Unopposed Motion") and state: 1. On May 1, 2007, plaintiff Donald Keller ("Plaintiff") served written discovery titled Plaintiff's First Combined Discovery Request (the "Written Discovery") on Defendants. The Written Discovery is extensive and includes numerous interrogatories, requests for admissions, and document production requests. 2. Defendants' response to the Written Discovery is currently due on June 4, 2007. Defendants' personnel with knowledge of this matter need additional time carefully to review and consider their response to the Written Discovery. As a result, Defendants seek in this Unopposed Motion a 30 day enlargement of time to respond to the Written Discovery (i.e. an enlargement to and including July 5, 2007). 3. Pursuant to D.C.COLO.LCivR 6.1(C), Defendants state that they have not previously sought any enlargement of time relating to their response to the Written Discovery. 4. Pursuant to D.C.COLO.LCivR. 6.1(D), and as evidenced by the certificate of service below, Defendants' undersigned counsel has served a copy of this Unopposed Motion upon a representative of both defendant Qwest Communications International Inc. and defendant Qwest Asset Management Company.

Case 1:04-cv-00680-REB-CBS

Document 31

Filed 05/22/2007

Page 2 of 3

5. Pursuant to D.C.COLO.LCivR 7.1(A), Defendants' undersigned counsel has conferred with Plaintiff's counsel. Plaintiff does not object to this Unopposed Motion and stipulates to the entry of the relief requested. WHEREFORE, Defendants respectfully request entry of an order granting this Unopposed Motion and allowing Defendants to and including July 5, 2007 in which to respond to the Written Discovery. Defendants have submitted a proposed form of order with this motion. Dated this 22nd day of May, 2007. _s/Michael B. Carroll______________ Michael B. Carroll William A. Wright. SHERMAN & HOWARD L.L.C. 633 Seventeenth Street, Suite 3000 Denver, Colorado 80202 Telephone: (303) 297-2900 Facsimile: (303) 298-0940 ATTORNEYS FOR DEFENDANTS QWEST COMMUNICATIONS INTERNATIONAL INC. AND QWEST ASSET MANAGEMENT COMPANY

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Case 1:04-cv-00680-REB-CBS

Document 31

Filed 05/22/2007

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on May 22nd, 2007, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following counsel at the following e-mail address: Perry J. Schneider, Esq. Milodragovich, Dale, Steinbrenner & Binney, P.C. P.O. Box 4947 Missoula, MT 59806-4947 E-Mail: [email protected] Attorney for Plaintiff Donald Keller

I also hereby certify that on May 22nd, 2007, I mailed a copy of the foregoing in the regular U.S. mail, postage pre-paid, addressed to the following: Heather Shull, Esq. Qwest Communications International Inc. 1801 California, 9th Floor Denver, CO 80202 For Qwest Communications International, Inc and Qwest Asset Management Company s/Kathy Norris Kathy Norris

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