Free Motion for Extension of Time to File Response/Reply - District Court of Colorado - Colorado

Case 1:03-cv-02355-RPM

Document 46

Filed 08/31/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-2355-RPM LEONID DMITRUK, Administrator of the Estate of Alexander Bugaychuk, deceased, and YELENA BUGAYCHUK, an individual, and NATALIA MELNIK an individual, and IRINA MOROZOV, personally and as administrator of the Estate of Yevgeniy Morozov, deceased, and as Guardian for SARA MOROZOV, a minor, and ELEANNA MOROZOV, a minor, Plaintiffs, v. GEORGE AND SONS' REPAIR SHOP, INC, a Colorado corporation, d.b.a. "George's Towing", GEORGE ROSLER, a resident of the State of Colorado. Defendants. ______________________________________________________________________________ UNOPPOSED MOTION FOR EXTENSION OF TIME IN WHICH TO RESPOND TO MOTIONS FOR SUMMARY JUDGMENT ______________________________________________________________________________ COME NOW the Defendants George and Sons' Repair Shop, Inc., d.b.a. George's Towing, and George Rosler, by and through their attorney, Andrew J. Carafelli, of Hall & Evans, L.L.C. and files their Unopposed Motion for Extension of Time in Which to Respond to Motions for Summary Judgment as follows: CERTIFICATE OF COMPLIANCE Pursuant to Loc.R. 7.1A, the undersigned has conferred with opposing counsel regarding the relief sought in this Motion and opposing counsel does not oppose the Motion.

Case 1:03-cv-02355-RPM

Document 46

Filed 08/31/2005

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That Motions for Summary Judgment in this matter were due to be filed on or before

August 15, 2005. That these Defendants filed their Motion for Summary Judgment on August 11, 2005 and Plaintiffs have also filed their own Motion for Summary Judgment as to one claim on August 14, 2005. 2. That the responses to each of the Motions for Summary Judgment would be due on

or before September 5, 2005. 3. That the undersigned was out of the country on vacation between August 13 and

August 28, returning to the office on August 29, 2005 when he first learned that Plaintiffs had filed a Motion for Summary Judgment. 4. That the undersigned has conferred with Plaintiffs' counsel who was also on a

vacation of his own during this period of time and both parties have agreed that an extension to respond to each other's Motions for Summary Judgment would be appropriate. 5. That the parties would request through and including September 13, 2005 in which

to respond to the Motions for Summary Judgment in this matter. Dated this 31st day of August 2005. Respectfully submitted, /s Andrew J. Carafelli Andrew J. Carafelli HALL & EVANS, L.L.C. 1125 17th Street, Suite 600 Denver, CO 80202 (303) 628-3300 ATTORNEYS FOR DEFENDANTS

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Case 1:03-cv-02355-RPM

Document 46

Filed 08/31/2005

Page 3 of 3

CERTIFICATE OF SERVICE (CM/ECF) I HEREBY CERTIFY that on the 31st day of August 2005, I electronically filed the foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME IN WHICH TO RESPOND TO MOTIONS FOR SUMMARY JUDGMENT with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Komron M. Allahyari, Esq. Washington Law Group 1001 Fourth Avenue Plaza, 32nd Floor Seattle, WA 98154 E-mail: [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 (mail, hand-delivery, etc.) indicated by the non-participant's name: Via U.S. Mail, postage prepaid addressed to the following: Ms. Jacqueline Adamson Director, Major Case Liability Northland Insurance Company P.O. Box 64805 St. Paul, MN 55164-0805 Mr. George Rosler c/o George's Repair Shop 199 Main Street Limon, CO 80828

s/Leslie E Grauberger, Secretary Andrew J. Carafelli, Esq. Hall & Evans, L.L.C. 1125 17th Street, Suite 600 Denver, CO 80202-2052 303-628-3300 303-293-3231 ­ Fax [email protected] ATTORNEYS FOR DEFENDANTS

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