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

Case 1:03-cv-02579-RPM

Document 190

Filed 09/10/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-02579-RPM NATIONAL OILWELL VARCO, L.P., Plaintiff, v. PASON SYSTEMS USA CORP., Defendant.

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSIVE TRIAL BRIEFS
Pursuant to D.C.COLO.LCivR 7.1(A) and 6.1(C), Plaintiff National Oilwell Varco, L.P. ("Varco"), by and through its counsel, respectfully requests an extension of time, to and including September 19, 2008, for the parties to file their responsive trial briefs. As grounds for this Motion, Varco states to the Court as follows: 1. Pursuant to the Amended Final Pretrial Order [Document # 174], the parties'

Responsive Trial Briefs are due on Friday, September 12, 2008. 2. As a result of the advancement of Hurricane Ike, which is predicted to make

landfall in Texas within the next 48 hours, the citizens of Houston are on evacuation alert. 3. Plaintiff's Texas co-counsel, Robert E. Bowick and John W. Raley, III, are in the

process of making their evacuation plans, and they may be unable to return to their offices prior to the current September 12th filing deadline.

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Case 1:03-cv-02579-RPM

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4.

As required by D.C.COLO.LCivR 7.1(A), the undersigned counsel has conferred

with counsel for Defendant and is authorized to state that Defendant has no objection to this Motion, which would extend the filing deadline for both parties. 5. Pursuant to D.C.COLO.LCivR 6.1(E), a copy of this unopposed Motion is being

served on the undersigned's client and all counsel of record. Wherefore, Varco respectfully requests that the Court grant an extension of time, to and including September 19, 2007, within which the parties may file their Responsive Trial Briefs. Respectfully submitted this 10th day of September, 2008. s/Jane Michaels Jane Michaels Ryan T. Bergsieker Holland & Hart LLP 555 17th Street, Suite 3200 Denver, CO 80202 Phone: 303-295-8000 Facsimile: 303-295-8261 Robert M. Bowick Matthews, Larson & Bowick PLLC 2000 Bering, Suite 700 Houston, TX 77057 Phone: 713-355-4200 Facsimile: 713-355-9689 John W. Raley, III Cooper & Scully, P.C. 700 Louisiana Street, Suite 3850 Houston, TX 77002 Phone: 713-236-6801 Facsimile: 713-236-6880 Attorneys for Plaintiff National Oilwell Varco, L.P.

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Case 1:03-cv-02579-RPM

Document 190

Filed 09/10/2008

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CERTIFICATE OF SERVICE
I hereby certify that on September 10, 2008, I caused the following to be electronically filed with the Clerk of the Court using CM/ECF system which will send notification of such filing to the following email addresses: [email protected] [email protected] [email protected] [email protected] I hereby certify that on September 10, 2008, I caused to be mailed via electronic mail and United States mail, postage prepaid, the foregoing pleading to: Cormac Creaven National Oilwell Varco, L.P. PO Box 4888 Houston, TX 77210 [email protected] s/ Jane Michaels
3921944_1.DOC

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