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

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

Document 52

Filed 03/30/2006

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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. ______________________________________________________________________________ UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S MOTION FOR RELIEF FROM ENTRY OF SUMMARY JUDGMENT ______________________________________________________________________________ Defendant Celestica Corporation ("Celestica"), hereby respectfully submits its Unopposed Motion for Extension of Time to Respond to Plaintiff's Motion for Relief from Entry of Summary Judgment (the "Unopposed Motion"). In support of its Unopposed Motion, Defendant states as follows: 1. Defendant is currently required to respond to Plaintiff's Motion for Relief from

Entry of Summary Judgment on or before April 5, 2006. 2. The parties have been engaged in discussions in an effort to resolve this matter

without need for further involvement of this Court. 3. To facilitate those discussions, Defendant respectfully requests an extension of

time, to and including April 19, 2006, to respond to Plaintiff's Motion for Relief from Entry of Summary Judgment.

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

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Filed 03/30/2006

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Certification Under D.COLO.LCivR. 7.1. The undersigned hereby certifies that,

prior to filing this Unopposed Motion, she conferred with counsel for Plaintiff, who indicated that Plaintiff does not oppose the extension of time requested by Defendant. WHEREFORE Defendant respectfully requests that the Court grant its Unopposed Motion and allow Defendant an extension of time, through and including April 19, 2006, to respond to Plaintiff's Motion for Relief from Entry of Summary Judgment. Respectfully submitted this 30th day of March, 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 03/30/2006

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CERTIFICATE OF SERVICE I hereby certify that on March 30, 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]

s/ Elizabeth S. McKelvey

DNVR1:60340040.01

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