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

Case 1:04-cv-01025-ZLW-BNB

Document 111

Filed 06/14/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-01025-ZLW-BNB DALE ASMUSSEN, Plaintiff, v. MARVIN WADE, in his individual capacity, and CYNDI LOVELL, in her individual capacity, Defendants. ______________________________________________________________________________ DEFENDANTS' UNOPPOSED MOTION TO EXTEND DEADLINE TO FILE SETTLEMENT PAPERS ______________________________________________________________________________ Defendants, through their attorneys SEMPLE, MILLER, MOONEY & FARRINGTON, P.C., by Patrick B. Mooney and Matt Ratterman, pursuant to Fed. R. Civ. P. 6(b) and D.C.COLO.LCivR 6.1, hereby move for an extension of time to file settlement papers. In support hereof, Defendants state: 1. By Order of this Court dated June 7, 2006, the parties are required to file

settlement papers in this case by June 21, 2006. 2. The proposed settlement agreement is subject to approval by the Board of

Education of the Weld County School District RE3-J (the "Board"). 3. The Board will consider this matter at its next meeting, scheduled for the evening

of June 21, 2006.

Case 1:04-cv-01025-ZLW-BNB

Document 111

Filed 06/14/2006

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4.

Because the Board will not act until the evening of the deadline date to file

settlement papers, the parties require additional time to file the settlement papers with the Court. 5. Pursuant to D.C.COLO.L.CivR 7.1(A), counsel for the parties conferred and have

agreed to seek an extension of one week. 6. 7. This short extension will not prejudice either party. This is the first extension either party has requested to file settlement papers.

WHEREFORE, Defendants request a one-week extension of time, up to and including June 28, 2006, for the parties to file settlement papers with this Court. Respectfully submitted this 14th day of June, 2006. SEMPLE, MILLER, MOONEY & FARRINGTON, P.C. . s/Matt Ratterman ________________________________ Patrick B. Mooney, # 17380 ­ [email protected] Matt Ratterman, #32652 ­ [email protected] 1120 Lincoln Street, Suite 1308 Denver, CO 80203 ATTORNEYS FOR DEFENDANTS CERTIFICATE OF SERVICE I hereby certify that on the 14th day of June, 2006, a true and correct copy of the foregoing DEFENDANTS' UNOPPOSED MOTION TO EXTEND DEADLINE TO FILE SETTLEMENT PAPERS was filed and served via CM/ECF to the following: Cathy L. Cooper, Esq. Colorado Education Association 1500 Grant Street Denver, CO 80203 Dr. Marvin Wade, Superintendent Weld County School District No. RE-3 Post Office Box 269 Keenesburg, CO 80643 2

Case 1:04-cv-01025-ZLW-BNB

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Filed 06/14/2006

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Ms. Cyndi Lovell Weld County School District No. RE-3 Post Office Box 269 Keenesburg, CO 80643 s/Tammi J. Evans ______________________________

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