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

Case 1:03-cv-02475-WDM-CBS

Document 68

Filed 12/29/2005

Page 1 of 5

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 03-cv-02475-WDM-CBS JAYVANTI, a/k/a WENDY JAYVANTI, Plaintiff, v. DEVEREUX CLEO WALLACE, a non-profit corporation, and the DEVEREUX CLEO WALLACE FOUNDATION, a non-profit corporation, Defendants.

DEFENDANTS' UNOPPOSED MOTION TO EXTEND DEADLINE TO SUBMIT STIPULATION FOR DISMISSAL with Proposed Order

Defendants Devereux Cleo Wallace and Devereux Cleo Wallace Foundation, by and through their attorney, Andrew D. Ringel, Esq. of Hall & Evans, L.L.C., hereby submit this Unopposed Motion to Extend Deadline to Submit Stipulation for Dismissal, and as grounds therefore state as follows: 1. In a Minute Order dated December 20, 2005, this Court set a deadline of January 6, 2006,

for the parties to submit a stipulation for dismissal. Despite diligent efforts, due to logistical issues and the Christmas and New Years Day holidays, the parties require additional time to finalize the appropriate settlement documents and submit a stipulation for dismissal to this Court. Accordingly, Defendants respectfully requests an extension of ten (10) days until and including January 16, 2006, for the parties to submit a stipulation for dismissal to this Court.

Case 1:03-cv-02475-WDM-CBS

Document 68

Filed 12/29/2005

Page 2 of 5

2

Case 1:03-cv-02475-WDM-CBS

Document 68

Filed 12/29/2005

Page 3 of 5

2.

Pursuant to D.C.Colo.L.Civ.R. 7.1(A) counsel for the Defendants spoke to counsel for the

Plaintiff, Elwyn Schaefer, Esq. by telephone on December 29, 2005, prior to filing the instant Motion. Mr. Schaefer indicated the Plaintiff does not oppose this Motion. 3. Pursuant to D.C.Colo.LCiv.R. 6.1(D), the undersigned counsel has served his client

representative with a copy of this Motion as indicated on the attached Certificate of Service. WHEREFORE, for all the foregoing reasons, Defendants Devereux Cleo Wallace Foundation and Devereux Cleo Wallace respectfully requests this Court issue an Order extending the deadline for the parties to submit a stipulation for dismissal to this Court by ten (10) days until and including January 16, 2006, and for such other relief as the Court finds just and appropriate. Dated this 29th day of December, 2005. Respectfully submitted, s/ Andrew D. Ringel______________ Andrew D. Ringel, Esq. of HALL & EVANS, L.L.C. 1125 Seventeenth Street, Suite 600 Denver, Colorado 80202-2037 (303) 628-3300 [email protected] ATTORNEYS FOR DEFENDANTS

3

Case 1:03-cv-02475-WDM-CBS

Document 68

Filed 12/29/2005

Page 4 of 5

CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on the 29th day of December, 2005, I electronically filed the foregoing DEFENDANTS' UNOPPOSED MOTION TO EXTEND DEADLINE TO SUBMIT STIPULATION FOR DISMISSAL with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail address: Elwyn F. Schaefer, Esq. Andrea J. Kershner, Esq. Elwyn F. Schaefer & Associates, P.C. 600 17th Street, Suite 2005 South Denver, Colorado 80202 [email protected] Scott F. Reese, Esq. Scott F. Reese, P.C. 795 W. Birch Ct., Suite 100 Louisville, Colorado 80027 [email protected] and placed a true and correct copy in the United States Mail, first-class postage prepaid, and addressed to the following: Lori McLaughlin, Esq. Corporate General Counsel Devereux Foundation 2012 Renaissance Blvd. King of Prussia, PA 19406

s/ Loree Trout, Secretary Andrew D. Ringel, Esq. Hall & Evans, L.L.C. 1125 17th Street, Suite 600 Denver, CO 80202-2052 (303) 628-3300 ph. (303) 628-3368 fax [email protected] 4

Case 1:03-cv-02475-WDM-CBS

Document 68

Filed 12/29/2005

Page 5 of 5

ATTORNEYS FOR DEFENDANTS

H:\Users\RINGELA\Devereux\Devereux-Jayvanti\gen pleadings\extend stipulation.doc

5