Free Motion to Supplement - District Court of Colorado - Colorado

Case 1:04-cv-00558-MSK-OES

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO __________________________________________________________________ Civil Action No. 1:04-cv-00558 (MSK)(OES) DEBORAH DIXON, Plaintiff, vs. DENVER HEALTH AND HOSPITAL AUTHORITY, Defendant.

________________________________________________________________________ PLAINTIFF'S MOTION TO FILE SUPPLEMENTAL AUTHORITIES TO RESPONSE TO MOTION FOR SUMMARY ADJUDICATION ________________________________________________________________________ Plaintiff, by and through her attorney, Karen Larson, hereby moves the Court for leave to supplement her authorities to her Response to Motion for Summary Adjudication, and as grounds she states: 1. Plaintiff supplements the authorities in this case in support of her

Response to Motion for Summary Judgment to add some case law that was decided after Plaintiff filed her Response to Motion for Summary Judgment and some case law that existed at the time of Plaintiff's Response to Motion for Summary Adjudication and will assist the Court in deciding Defendant's Motion for summary Judgment. Pursuant to Local Rule 7.1 E., Supplemental Authorities may be filed at least five (5) days before a hearing set in the matter. 2. The District Court Rules on Civil Procedure are silent regarding the

circumstances under which Supplemental Authorities may be filed; however, The Federal

Case 1:04-cv-00558-MSK-OES

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Rules of Appellate Procedure, Rule 28 (j) allow for the filing of Supplemental Authorities without leave of Court when pertinent and significant authorities come to a party's attention after the party's brief has been filed. 3. Plaintiff contacted the Defendant's attorney, Brent Johnson, by email on

October 11, 2005 pursuant to Local Rule 7.1 A to confer with him regarding the filing of this motion. Mr. Johnson objects to the supplementation by any authority that existed at the time Plaintiff filed her Response to Motion for Summary Adjudication. WHEREFORE, Plaintiff respectfully requests the Honorable Court GRANT her Motion to File Supplemental Authorities. DATED this 11th day of October, 2005. Respectfully submitted,

s/Karen Larson________ Karen Larson Karen Larson 1120 Lincoln Street, Suite 711 Denver, CO 80203 Telephone:303-831-4404 FAX: 303-830-8843 Email: [email protected] Attorney for Plaintiff

CERTIFICATE OF MAILING I certify that on this 11th 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 email addresses: [email protected] s/Karen Larson________ Karen Larson

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Karen Larson 1120 Lincoln Street, Suite 711 Denver, CO 80203 Telephone:303-831-4404 FAX: 303-830-8843 Email: [email protected]

DATED this 11th day of October, 2005.

Respectfully submitted,

s/Karen Larson________ Karen Larson Karen Larson 1120 Lincoln Street, Suite 711 Denver, CO 80203 Telephone:303-831-4404 FAX: 303-830-8843 Email: [email protected] Attorney for Plaintiff

CERTIFICATE OF MAILING I certify that on this 11th 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 email addresses: [email protected]

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s/Karen Larson________ Karen Larson Karen Larson 1120 Lincoln Street, Suite 711 Denver, CO 80203 Telephone:303-831-4404 FAX: 303-830-8843 Email: [email protected]

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