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

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

Document 102

Filed 11/18/2005

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IN THE UNITED STATES DISTRICT COURT IN AND FOR THE DISTRICT OF COLORADO Civil Action No.: 04-CV-1025-ZLW-BNB DALE ASMUSSEN, Plaintiff, v. MARVIN WADE, in his individual capacity, and CYNDI LOVELL, in her individual capacity, Defendants.

STIPULATED MOTION FOR EXTENSION OF TIME TO FILE OBJECTIONS TO EXHIBITS

The parties, through their counsel of record, hereby stipulate to this motion for an extension of time to file their respective objections to the exhibit lists filed by the parties through and including November 28, 2005. As grounds therefor, the parties state as follows: 1. Certification: Pursuant to D.C.Colo.L.Civ.R. 7.1A, counsel for the parties have

conferred and agreed to request an extension of time through and including November 28, 2005 in which to file their objections. Counsel for Defendants has authorized the undersigned to represent to the Court that Defendants stipulate to this motion. 2. 3. Objections to the exhibits filed by the parties are presently due November 18, 2005. Due to the press of business and personal issues requiring the immediate attention

of Plaintiff's counsel (specifically, Plaintiff's counsel's need to attend to an unexpected medical issue regarding the health of counsel's elderly father), counsel have been unable to devote
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Case 1:04-cv-01025-ZLW-BNB

Document 102

Filed 11/18/2005

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sufficient time to review and object to exhibits filed by Defendants by the present due date of November 18, 2005. 4. The parties are requesting an extension of five business days. Trial in this matter

is set for July 10, 2006, and a brief extension will prejudice no party. WHEREFORE, the parties respectfully request the Court grant until the close of business November 28, 2005 in which to file their respective objections to the exhibit lists filed by the parties on October 28, 2005. DATED this 18th day of November, 2005. Respectfully submitted,

/s/ Cathy L. Coooper Cathy L. Cooper, Esq. Colorado Education Association 1500 Grant Street Denver, CO 80203 Telephone: 303-837-1500 Facsimile: 303-861-2039 Email: [email protected] Attorneys for Plaintiff

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

Document 102

Filed 11/18/2005

Page 3 of 3

CERTIFICATE OF SERVICE (CM/ECF) The undersigned certifies that a true and correct copy of the within STIPULATED MOTION FOR EXTENSION OF TIME TO FILE OBJECTIONS TO EXHIBITS was filed with the Clerk of the Court using the CM/ECF system on November 18, 2005, which will send notification of such filing to the following counsel for Defendant via the email address on file with the Court: Patrick B. Mooney, Esq. Matt Ratterman, Esq. Semple, Miller, Mooney & Farrington, P.C. 1120 Lincoln Street, Suite 1308 Denver, CO 80203 [email protected] and placed in a U. S. Mail Depository, first class postage prepaid, addressed to: Dale Asmussen 1620 3rd Street, S.W. Loveland, CO 80537 /s/ P. J. Morris

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