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

Case 1:04-cv-00023-LTB

Document 75

Filed 05/15/2008

Page 1 of 4

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-00023-LTB-CBS THOMAS MINK, Plaintiff, v. SUSAN KNOX, a Deputy District Attorney working for the 19th Judicial District Attorney's Office, in her individual capacity, Defendant. ______________________________________________________________________________ DEFENDANT'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO SUBMIT REPLY BRIEF IN SUPPORT OF RENEWED MOTION TO DISMISS with proposed Order ______________________________________________________________________________ Defendant Susan Knox, by and through her counsel, David R. Brougham, Esq. and Andrew D. Ringel, Esq. of Hall & Evans, L.L.C., hereby submits this Unopposed Motion for Extension of Time to Submit Reply Brief in Support of Renewed Motion to Dismiss, and as grounds therefore states as follows: 1. Pursuant to this Court's Minute Order dated April 25, 2008, Defendant's Reply

Brief in Support of Renewed Motion to Dismiss is due on May 15, 2008. Defendant now respectfully requests an extension of seven (7) days until and including May 22, 2008, in which to submit her Reply Brief in Support of Renewed Motion to Dismiss in this case. 2. The undersigned counsel has the responsibility for researching and drafting the

Defendant's Reply Brief in Support of Renewed Motion to Dismiss in this matter. In addition, the undersigned counsel has had and has the following other additional responsibilities in a

Case 1:04-cv-00023-LTB

Document 75

Filed 05/15/2008

Page 2 of 4

variety of other different matters: (a) a response to a charge of discrimination and request for information to the Colorado Civil Rights Division due May 9, 2008; (b) a Surreply in Support of Motion to Dismiss in Suzanne Phillipus, individually and as personal representative of the Estate of Terry Phillipus, deceased v. Aetna Health, Inc. and Time Warner Telecom, Inc., United States District Court for the District of Colorado, Civil Action No. 07-cv-02682-JLK due on May 9, 2008; (c) discovery responses in Aaron Spatziani v. Corrections Corporation of America et. al., United States District Court for the District of Colorado, Civil Action No. 07-cv-01234-RPMMEH, due May 15, 2008; (d) depositions in Aaron Spatziani v. Corrections Corporation of America et. al., United States District Court for the District of Colorado, Civil Action No. 07-cv01234-RPM-MEH, on May 19, 2008, in Pueblo, Colorado; and (e) negotiations and finalization of settlements in two other matters. Accordingly, Defendant respectfully requests an extension of seven (7) days until and including May 22, 2008, to file her Reply Brief in Support of Renewed Motion to Dismiss with this Court. No party will be prejudiced by this brief extension of time. 3. Pursuant to D.C.Colo.LCiv.R. 7.1(A), the undersigned counsel for the Defendant

contacted counsel for the Plaintiff, A. Bruce Jones, Esq., to inform him of the Defendant's intent to file the instant Motion. Mr. Jones indicated the Plaintiff does not object to this requested extension of time. 4. Pursuant to D.C.Colo.LCiv.R. 6.1(E), undersigned counsel has served his client

and all counsel with a copy of this Motion as indicated on the certificate of service. WHEREFORE, for all of the foregoing reasons, Defendant Susan Knox respectfully requests this Court grant her an extension of time until and including May 22, 2008, within

2

Case 1:04-cv-00023-LTB

Document 75

Filed 05/15/2008

Page 3 of 4

which to file her Reply Brief in Support of Renewed Motion to Dismiss, and for all other and further relief as this Court deems just and appropriate. Dated this 15th day of May, 2008. Respectfully submitted,

s/ Andrew D. Ringel . Andrew D. Ringel, Esq. Hall & Evans, L.L.C. 1125 17th Street, Suite 600 Denver, CO 80202-2052 303-628-3453 Fax: 303-293-3238 [email protected] ATTORNEYS FOR DEFENDANT

3

Case 1:04-cv-00023-LTB

Document 75

Filed 05/15/2008

Page 4 of 4

CERTIFICATE OF SERVICE (CM/ECF) I HEREBY CERTIFY that on the 15th day of May, 2008, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: A. Bruce Jones, Esq. Holland & Hart, L.L.P. [email protected] Marcy G. Glenn, Esq. Holland & Hart, L.L.P. [email protected] Mark Silverstein, Esq. ACLU 400 Corona Street Denver, CO 80218 [email protected] [email protected] and I hereby certify that I have mailed or served the document or paper to the following non CM/ECF participants in the manner indicated by the non-participant's name: Susan Knox, Esq. U.S. Attorney's Office 1225 17th St., #700 Denver, CO 80202

s/ Loree Trout, Secretary to Andrew D. Ringel, Esq. Hall & Evans, L.L.C. 1125 17th Street, Suite 600 Denver, CO 80202-2052 303-628-3453 Fax: 303-293-3238 [email protected]

.

ATTORNEYS FOR DEFENDANT
H:\Users\RINGELA\weld\Mink 6271-445\USDC pleadings\extend motion2.doc

4