Free Motion to Amend/Correct/Modify - District Court of Colorado - Colorado

Case 1:03-cv-02579-RPM

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Filed 08/14/2006

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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, v. PASON SYSTEMS USA CORP., Defendant. DEFENDANT PASON'S UNOPPOSED SECOND MOTION TO AMEND THE SUPPLEMENTAL SCHEDULING ORDER TO EXTEND THE DEADLINE FOR REBUTTAL EXPERT DESIGNATIONS The Defendant, Pason Systems, USA Corp. ("Pason"), through counsel, requests a brief and mutual extension of time for the parties to file rebuttal expert designations, and states the following in support. 1. On or about July 14, 2006, Pason requested that the deadline for file expert

designations and rebuttal expert designations, as contained in the Supplemental Scheduling Order entered in this case, be extended. 2. On July 17, 2006, this Court granted that Motion and set the deadline for both

parties to file initial expert reports for July 21, 2006 and for both parties to file rebuttal expert reports for August 21, 2006. 3. The professional schedules of the rebuttal expert(s) and recent discovery burdens

in this case have made it impossible to timely complete the rebuttal expert report(s).

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4.

Pason respectfully requests an enlargement of the period for both parties to file

rebuttal expert designations be extended to Tuesday, September 5, 2006. 5. This is the second extension or modification of the Supplemental Scheduling

Order sought by either party and it will not cause any prejudice or delay of the proceedings in this case. 6. Pason has conferred with Mr. Robert Bowick, counsel for the Plaintiff, who has

authorized the undersigned to state that Plaintiff has no objection to the requested extension. Pason therefore certifies compliance with D.C.Colo.LCiv.R. 7.1(A). Respectfully submitted this 14th day of August 2006.

IRELAND, STAPLETON, PRYOR AND PASCOE, P.C. _s/_Tim G. Atkinson_____________ Mark E. Haynes Tim G. Atkinson Barbara Weil Laff Ireland Stapleton Pryor and Pascoe, P.C. 1675 Broadway, Street 2600 Denver, Colorado 80202 (303) 623-2700 Phone (303) 623-2062 Fax ATTORNEYS FOR DEFENDANT PASON SYSTEMS USA CORP.

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CERTIFICATE OF MAILING I hereby certify that August 14, 2006, a true and correct copy of the foregoing DEFENDANT PASON'S UNOPPOSED SECOND MOTION TO AMEND THE SUPPLEMENTAL SCHEDULING ORDER TO EXTEND THE DEADLINE FOR REBUTTAL EXPERT DESIGNATIONS was filed with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail 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 And, pursuant to D.C. Colo. L.R. 6.1.D., to our client: Mr. Greg Lindsay Pason Systems USA Corp. 16080 Table Mountain Parkway Suite 500 Golden, CO 80403, USA _s/_Tim G. Atkinson______________ Mark E. Haynes Tim G. Atkinson Barbara Weil Laff Ireland Stapleton Pryor and Pascoe, P.C. 1675 Broadway, Street 2600 Denver, Colorado 80202 (303) 623-2700 Phone (303) 623-2062 Fax E-mail [email protected]

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