Free Motion for Extension of Time - District Court of Colorado - Colorado

Case 1:04-cv-00560-OES-BNB

Document 50

Filed 10/04/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-00560-OES-BNB

GEORGE M. BULL, Plaintiff, v. UNION PACIFIC RAILROAD COMPANY, a Delaware corporation, Defendant.

MOTION FOR EXTENSION OF TIME TO FILE PRE-TRIAL MOTIONS

COMES NOW, Defendant, Union Pacific Railroad Company, by and through its undersigned counsel, and hereby moves this Court for an extension of time to file pretrial motions, and as grounds therefore, states as follows: 1. 2005. 2. In order to file its pre-trial motions, Defendant must have a copy of the The deadline for filing pre-trial motions in this case is currently October 6,

deposition which it took of Plaintiff's expert, William Muzzy. This deposition was taken on August 18, 2005, in New Orleans, Louisiana. 3. As a result of the hurricanes which struck New Orleans, Defendant has

been unable to obtain a copy of this deposition from the court reporter. The court reporter who took this deposition may be able to provide Defendant with a copy of Mr. Muzzy's deposition early in the week of October 10, 2005.

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Case 1:04-cv-00560-OES-BNB

Document 50

Filed 10/04/2005

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4.

Counsel for Defendant contacted counsel for Plaintiff and requested an

extension of time to file pre-trial motions up to and including Monday, October 17, 2005. Counsel for Plaintiff refused this request. As such, counsel for Defendant has complied with the requirement to meet and confer prior to filing this Motion. WHEREFORE, Defendant, Union Pacific Railroad Company, hereby requests an extension of time up to and including Monday, October 17, 2005, in which to file its pretrial motions. Respectfully submitted this 4th day of October, 2005. Respectfully submitted,

_s/Mark C. Hansen_______ MARK C. HANSEN Union Pacific Railroad Company 1331 17TH Street, Suite 406 Denver, CO 80202 (303) 964-4583 FAX: (303) 964-4585

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Case 1:04-cv-00560-OES-BNB

Document 50

Filed 10/04/2005

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CERTIFICATE OF SERVICE I hereby certify that on this 4th day of October, 2005, 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 e-mail addresses: Donald C. Sinclair, II SINCLAIR KELLY JACKSON REINHART & HAYDEN 501 Corporate Drive Suite 200 Canonsburg, PA 15317 Sabina Y. Chung, Esq. Jack D. Robinson, Esq. SPIES, POWERS & ROBINSON, P.C. 1660 Lincoln Street, Suite 2220 Denver, CO 80264 Fredric A. Bremseth, Esq. Thomas W. Geng, Esq. BREMSETH LAW FIRM 810 East Lake Street Wayzata, MN 55391

[email protected]

[email protected]

[email protected]

I certify that there are no non CM/ECF participants in this case.

_s/Mark C. Hansen_______ MARK C. HANSEN Union Pacific Railroad Company 1331 17TH Street, Suite 406 Denver, CO 80202 [email protected]

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