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

Case 1:03-cv-02435-PSF-PAC

Document 271

Filed 10/03/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-02435-PSF-PAC LILLIAN F. SANDLE, Plaintiff, v. R. JAMES NICHOLSON, Secretary of Veterans Affairs, Defendant.

DEFENDANT'S MOTION FOR EXTENSION OF TIME TO SUBMIT PROPOSED PRETRIAL ORDER

Defendant R. James Nicholson, Secretary, Department of Veterans Affairs, by and through undersigned counsel, hereby moves pursuant to Rule 6(b)(1) of the Federal Rules of Civil Procedure for an additional one-day extension of time, to Wednesday, October 4, 2006, to file the parties' joint proposed pretrial order. As grounds for this motion, defendant states as follows: 1. Pursuant to this Court's Order filed October 3, 2006, the parties' proposed pretrial

order is due October 3, 2006. 2. In response to defendant's request for more specificity as to what claims would be

raised at trial, plaintiff sent an e-mail to defendant on Friday, September 29, 2006, which served to generally narrow the issues for trial. Having received this identification of

Case 1:03-cv-02435-PSF-PAC

Document 271

Filed 10/03/2006

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claims, the undersigned has been working diligently to cull through the thousands of pages of documents attendant to this case, which consists of seven EEO cases and years of alleged misconduct. The defendant is making every effort to streamline the issues and evidence to be presented to ensure the case is tried in the most efficient manner. The undersigned regrets any inconvenience posed to the Court or counsel as a result of this additional request for additional time. 3. 4. Plaintiff opposes this motion. Consequently, defendant respectfully requests that it be granted a one-day

extension of time, to Wednesday, October 4, 2006, to file the parties' proposed pretrial order. Dated this 3 rd day of October, 2006. Respectfully submitted, TROY A. EID United States Attorney s/ Michael C. Johnson MICHAEL C. JOHNSON Assistant United States Attorney 1225 Seventeenth Street, Suite 700 Denver, Colorado 80202 Telephone: (303) 454-0134 FAX: (303) 454-0408 E-mail: [email protected] Counsel for Defendant

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Case 1:03-cv-02435-PSF-PAC

Document 271

Filed 10/03/2006

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CERTIFICATE OF SERVICE I hereby certify that on this 3 rd day of October, 2006, I electronically filed the foregoing document with the Clerk of the Court using the CM/ECF system, which will send notification of such filing to the following e-mail addresses: Counsel for Plaintiff:

Dugan William Edward Bliss Email: [email protected] Sean Robert Gallagher Email: [email protected]

I hereby certify that on this 3 rd day of October, 2006, I served the foregoing document via electronic mail on the following non-CM/ECF participant: Agency Counsel: Thomas Kennedy [email protected]

s/ Michael C. Johnson MICHAEL C. JOHNSON Attorney for Defendant United States Attorney's Office 1225 Seventeenth Street, Suite 700 Denver, Colorado 80202 Telephone: (303) 454-0134 FAX: (303) 454-0408 E-mail: [email protected]

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