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

Case 1:03-cv-02528-WDM-OES

Document 91

Filed 11/21/2005

Page 1 of 3

THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-02528-WDM-OES DANNY O. DANIELS, Plaintiff, v. CITY AND COUNTY OF DENVER, Defendant.

__________________________________________________________________ UNOPPOSED MOTION FOR EXTENSION OF TIME TO AND INCLUDING DECEMBER 6, 2005 TO FILE A RESPONSE TO DEFENDANT'S MOTION FOR SANCTIONS __________________________________________________________________ Plaintiff Danny O. Daniels, by and through his attorneys, John D. Phillips and Marci A. Gilligan, respectfully requests the Court grant him an extension of time to and including December 6, 2005, in which to respond to Defendant's Motion for Sanctions. As grounds therefore, Mr. Daniels states as follows: 1. On November 9, 2005, Defendant filed a Motion for Sanctions

against Mr. Daniels. (Doc. 88). 2. The Court issued a Minute Order on November 10, 2005 granting

Mr. Daniels until November 21, 2005 to respond. (Doc. 90). 3. Discovery closes in this case on December 1, 2005.

Case 1:03-cv-02528-WDM-OES

Document 91

Filed 11/21/2005

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4. last week. 5.

The parties have been engaged in depositions over the course of the

As a result of the time constraints resulting from these depositions,

together with undersigned counsels' desire to more fully evaluate the merits of this case prior to providing a response to Defendant's motion for sanctions, Mr. Daniels believes it is in the best interests of the Court and the parties to address the motion for sanctions after the December 1, 2005 discovery deadline. 6. Mr. Daniels has not requested any prior extensions of time for filing

his response to Defendant's Motion for Sanctions. 7. Rule 7.1 Certification:

Undersigned counsel has communicated with Assistant City Attorney Karla J. Pierce about this motion and the reasons for requesting an extension of time. Ms. Pierce does not object to the requested extension of time.

Case 1:03-cv-02528-WDM-OES

Document 91

Filed 11/21/2005

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Respectfully submitted this 21st day of November, 2005.

s/Marci A. Gilligan___________ Marci A. Gilligan Richilano & Ridley, P.C. 1800 15th Street, Ste. 101 Denver, CO 80202 Phone: (303) 893-8000 Facsimile: (303) 893-8055 E-Mail: [email protected] John D. Phillips Shughart Thomson & Kilroy, PC 1050 Seventeenth St., Ste. 2300 Denver, CO 80265 Phone: (303) 572-9300 Facsimile: (303) 572-7883 E-Mail: [email protected] Attorneys for Plaintiff CERTIFICATE OF SERVICE I hereby certify that on this 21st day of November, 2005, I served a true and correct copy of the foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME TO AND INCLUDING DECEMBER 6, 2005 TO FILE A RESPONSE TO DEFENDANT'S MOTION FOR SANCTIONS via U.S. Mail, postage prepaid to the following: Karla J. Pierce, Esq. City Attorney's Office 201 W. Colfax Ave. #1108 Denver, CO 80202

s/Gwenn E. Miller____________ Gwenn E. Miller