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

Case 1:03-cv-02579-RPM

Document 121

Filed 11/09/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-CV-02579-RPM-BNB VARCO, L.P., Plaintiff, vs. PASON SYSTEMS USA CORP., Defendant. PLAINTIFF VARCO'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO SUBMIT PROPOSED FINAL PRETRIAL ORDER Plaintiff Varco respectfully requests an extension of four (4) business days to submit the proposed Final Pretrial Order. In support of this request, Varco states: 1. 2. 3. The Pretrial Conference is set for Friday, November 17, 2006. The proposed Final Pretrial Order is due today, Thursday, November 9, 2006. Counsel for the parties have been working diligently to limit the number of

potential exhibits and to narrow the areas of dispute. 4. A four (4) business day extension of time will allow counsel for the parties to

submit a more concise proposed Final Pretrial Order. This is the first request for an extension of this deadline by any party. 5. 6. A proposed Order reflecting this extension is attached. According to Local Rule 6.1(D), counsel for Varco certifies that she has provided

a copy of this Motion to her client.

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Case 1:03-cv-02579-RPM

Document 121

Filed 11/09/2006

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Dated: November 9, 2006 Respectfully submitted, s/ Jane Michaels Jane Michaels Joseph T. Jaros Ryan T. Bergsieker HOLLAND & HART LLP 555 Seventeenth Street, Suite 3200 Post Office Box 8749 Denver, Colorado 80201-8749 Tel. (303) 295-8000 Fax (303) 295-8261 [email protected] [email protected] [email protected] Guy E. Matthews Robert M. Bowick MATTHEWS, LAWSON, BOWICK & AL-AZEM, PLLC 2000 Bering Drive, Suite 700 Houston, Texas 77057 Tel. (713) 355-4200 Fax (713) 355-9689 [email protected] [email protected] ATTORNEYS FOR PLAINTIFF VARCO, L.P.

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Case 1:03-cv-02579-RPM

Document 121

Filed 11/09/2006

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CERTIFICATE OF SERVICE I hereby certify that, on November 9, 2006, 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: [email protected] [email protected]

s/ Jane Michaels I certify that on November 9, 2006 I caused to be served a true and correct copy of the foregoing Plaintiff Varco's Unopposed Motion for Extension of Time to Submit Proposed Final Pretrial Order to the following by: U.S. Mail, postage prepaid Hand Delivery Fax

Cormac Creaven, Esq. National Oilwell Varco 10000 Richmond Avenue Houston TX 77042 PO Box 4888 Houston, TX 77210 s/ Jane Michaels

3629568_2.DOC

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