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

Case 1:03-cv-02481-LTB-CBS

Document 55

Filed 04/19/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 1:03-cv-02481-LTB-CBS SUSAN VON FEIST, Plaintiff, v. CELESTICA CORPORATION, Defendant. ______________________________________________________________________________ JOINT MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S MOTION FOR RELIEF FROM ENTRY OF SUMMARY JUDGMENT ______________________________________________________________________________ Defendant Celestica Corporation ("Defendant"), for itself and on behalf of Plaintiff Susan Von Feist ("Plaintiff") hereby respectfully submits this Joint Motion for Extension of Time to Respond to Plaintiff's Motion for Relief from Entry of Summary Judgment (the "Joint Motion"). In support of this Joint Motion, Defendant states as follows: 1. Defendant requested and, by March 31, 2006 Order of the Court, was granted an

extension of time, through and including April 19, 2006, to respond to Plaintiff's Motion for Relief from Entry of Summary Judgment. 2. The parties have now reached a settlement of this matter and are in the process of

negotiating the terms of a confidential settlement agreement. The parties anticipate that both parties will have complied with all terms of the settlement by or before May 17, 2006, at which time they will dismiss this matter with prejudice.

Case 1:03-cv-02481-LTB-CBS

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3.

Accordingly, the parties jointly and respectfully request an extension of time,

through and including May 17, 2006, for Defendant to respond to Plaintiff's Motion For Relief From Entry Of Summary Judgment, or for the parties to file a stipulated motion to dismiss this action with prejudice. 4. Certification Under D.COLO.LCivR. 7.1. The undersigned hereby certifies that,

prior to filing this Joint Motion, she conferred with counsel for Plaintiff, who indicated that Plaintiff joins in the relief requested herein. WHEREFORE Plaintiff and Defendant respectfully request that the Court grant their Joint Motion and allow Defendant an extension of time, through and including May 17, 2006, to respond to Plaintiff's Motion for Relief from Entry of Summary Judgment, or for the parties to file a stipulated motion to dismiss this action with prejudice. Respectfully submitted this 19th day of April, 2006. FAEGRE & BENSON LLP

s/ Geri K. House Geri K. House Elizabeth S. McKelvey Geri K. House 3200 Wells Fargo Center 1700 Lincoln Street Denver, Colorado 80203 Telephone: (303) 607-3500 Facsimile: (303) 607-3600 ATTORNEYS FOR DEFENDANT CELESTICA CORPORATION

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Case 1:03-cv-02481-LTB-CBS

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Filed 04/19/2006

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CERTIFICATE OF SERVICE I hereby certify that on April 19, 2006, I electronically transmitted the attached document to the Clerk of Court using the ECF System for filing. Based on the records currently on file, the Clerk of court will transmit a Notice of Electronic Filing to the following ECF registrants: Elizabeth A. Starrs Justin G. Blankenship STARRS MIHM & CASCHETTE, LLP 1675 Broadway, Suite 1800 Denver, Colorado 80202 (303)592-5900 [email protected] [email protected] Cecilia M. Serna, Esq. Law Office of Cecilia M. Serna, Esq. 600 17th Street, Suite 2800 South Denver, Colorado 80202-5428

s/ Brenda Trujillo

DNVR1:60342488.01

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