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

Case 1:03-cv-02579-RPM

Document 119

Filed 11/08/2006

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I N T HE U NITED S TATES D ISTRICT C OURT F OR T HE D ISTRICT O F C OLORADO Civil Action No. 03-CV-02579-RPM-BNB VARCO, L.P., Plaintiff, vs. PASON SYSTEMS USA CORP., Defendant. PLAINTIFF'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY BRIEF IN SUPPORT OF ITS MOTION TO COMPEL DEFENDANT TO PRODUCE DOCUMENTS

Pursuant to D.C.COLO.LCivR 7.1, Plaintiff Varco, L.P. ("Varco"), by and through its attorneys, respectfully requests an extension of time of three business days within which to file a Reply Brief in support of its Motion To Compel Defendant To Produce Documents. As grounds for this request, Varco states to the Court as follows: 1. Varco filed a Motion To Compel Defendant To Produce Documents on

October 5, 2006 [Docket # 110]. 2. Defendant Pason Systems USA Corp. ("Pason") filed a Brief in

Opposition to Plaintiff's Motion To Compel Defendant To Produce Documents on October 25, 2006 [Docket # 117]. 3. Pursuant to D.C.COLO.LCivR 7.1(C), Varco's Reply Brief in support of

its Motion To Compel Defendant To Produce Documents is to be filed on or before November 9, 2006. 1

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4.

Varco requests an extension of three business days, to and including

November 14, 2006, within which to file its Reply Brief. 5. 6. Varco has not previously sought an extension as to this particular matter. The undersigned counsel has conferred with counsel for Defendant and is

authorized to state that Defendant does not object to this request. 7. Pursuant to D.C.COLO.LCivR. 6.1(D), the undersigned counsel certifies

that she has sent a copy of this motion to her client. WHEREFORE, Plaintiff respectfully requests an extension of time of three business days, up to and including November 14, 2006, within which to file a Reply Brief in support of its Motion To Compel Defendant To Produce Documents.

Dated this 8th day of November, 2006. Respectfully submitted,

s/Jane Michaels Jane Michaels Joseph T. Jaros Ryan T. Bergsieker H OLLAND & H ART 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

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M ATTHEWS , L AWSON , B OWICK & A L -A ZEM , 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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C ERTIFICATE O F S ERVICE I hereby certify that on November 8, 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 _________________________

3629568_2.DOC

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