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

Case 1:03-cv-02579-RPM

Document 111

Filed 10/09/2006

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

DEFENDANT'S UNOPPOSED MOTION FOR ONE-DAY ENLARGEMENT OF TIME TO FILE BRIEF IN OPPOSITION TO MOTION TO STRIKE DEFENDANT'S SUPPLEMENTAL DESIGNATION OF EXPERT OPINION Defendant Pason Systems USA Corp. ("Pason"), through its undersigned counsel, respectfully requests this Court grant Defendant a one-day enlargement of time to file its Brief in Opposition to Plaintiff's Motion to Strike Defendant's Supplemental Designation of Expert Opinion (the "Motion to Strike" or "Motion"). As grounds, Defendants state: 1. Complying with Varco's discovery requests, including reviewing approximately

60,000 e-mails, has been very time-consuming and has delayed the preparation of this Brief. 2. The undersigned counsel conferred with Jane Michaels, counsel for the Plaintiff,

regarding Defendant's request for a one-day enlargement of time to complete its Brief in Opposition to Plaintiff's Motion to Strike Defendant's Supplemental Designation of Expert Opinion, and is authorized to state Plaintiff does not object to Defendants' request.

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Case 1:03-cv-02579-RPM

Document 111

Filed 10/09/2006

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WHEREFORE, the Defendant respectfully requests a two-day enlargement of time, up to and including Tuesday, October 10, 2006, to file its Brief in Opposition to Plaintiff's Motion to Strike Defendant's Supplemental Designation of Expert Opinion. Dated October 9, 2006.

/s Mark E. Haynes Timothy G. Atkinson Mark E. Haynes Mark E. Lacis Ireland, Stapleton, Pryor & Pascoe, P.C. 1675 Broadway, Suite 2600 Denver, CO 80202 Telephone: 303-623-2700 Facsimile: 303-623-2062 E-mail: [email protected] CERTIFICATE OF MAILING I hereby certify that on October 9, 2006, a true and correct copy of the foregoing DEFENDANT'S UNOPPOSED MOTION FOR ONE-DAY ENLARGEMENT OF TIME TO FILE BRIEF IN OPPOSITION TO MOTION TO STRIKE DEFENDANT'S SUPPLEMENTAL DESIGNATION OF EXPERT OPINION was filed with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following email address: [email protected]. And, via U.S. Mail to: Guy E. Matthews, Esq. Robert M. Bowick, Esq. MATTHEWS, LAWSON, BOWICK & AL-AZEM, PLLC 2000 Bering Drive, Suite 700 Houston, Texas 77057

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Case 1:03-cv-02579-RPM

Document 111

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Greg Lindsay, U.S. General Manager Pason Systems USA Corp. 16080 Table Mountain Parkway Suite 500 Golden, CO 80403 /s Mark E. Haynes Timothy G. Atkinson Mark E. Haynes Mark E. Lacis Ireland, Stapleton, Pryor & Pascoe, P.C. 1675 Broadway, Suite 2600 Denver, CO 80202 Telephone: 303-623-2700 Facsimile: 303-623-2062 E-mail: [email protected]

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