Free Motion to Continue - District Court of Colorado - Colorado

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

Document 218

Filed 06/28/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 03-CV-02435-PSF-PAC (consolidated with 04-cv-00639-PSF-PAC)

LILLIAN F. SANDLE, Plaintiff, v. ANTHONY J. PRINCIPI, Secretary of Veterans Affairs, Defendant,

and Consolidated Civil Action No. 04-cv-00639-PSF-PAC LILLIAN F. SANDLE, Plaintiff, v. ANTHONY J. PRINCIPI, ED SANCHEZ, RAYMOND DELUNA, and E. THORSLAND, JR. Defendants.

JOINT MOTION TO CONTINUE SETTLEMENT CONFERENCE

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

Document 218

Filed 06/28/2006

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The parties to the above-captioned consolidated cases, by and through their counsel of record, hereby move to continue the settlement conference in this case, presently scheduled for July 6, 2006, to a time convenient to the Court on or after September 20, 2006. The basis for continuing the settlement conference to a date on or after September 20, 2006 is as follows: 1. Plaintiff has identified over 30 separate alleged adverse employment acts at issue

in this Title VII case, and over 20 alleged failures to abide by the terms of the Rehabilitation Act. 2. The parties are presently engaged in discovery in this matter. The discovery cut-

off date, at the present time, is not until July 23, 2006. The parties have presently scheduled a number of depositions to occur in the next four weeks. 3. Defendants anticipate filing a motion for summary judgment on or about August

23, 2006, the dispositive motion cut-off date, following the completion of discovery. Plaintiff anticipates filing a response to defendants' motion 20 days thereafter.. 4. Given the complexity of the case at the present time, including the number of

claims at issue here, the parties do not anticipate being able to formulate their settlement positions until after (1) discovery is completed, (2) defendants have filed their summary judgment motion, and (3) plaintiff has filed her opposition to the motion. Wherefore, the parties submit that settlement discussions in this case will be most productive if those discussions take place after plaintiff has filed her opposition to 2

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

Document 218

Filed 06/28/2006

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defendants' summary judgment motion. Consequently the parties respectfully move to continue the settlement conference to a date on or after September 20, 2006. DATED this 27 th day of June, 2006.

s/ Dugan W. Bliss Sean R. Gallagher Elizabeth K. Pietsch Dugan W. Bliss Hogan & Hartson LLP 1200 17 th Street, Suite 1500 Denver, CO 80202-5835 Telephone: (303) 899-7300 Fax: (303) 899-7333 Attorney for Plaintiff Lillian F. Sandle

WILLIAM J. LEONE United States Attorney s/ Michael C. Johnson MICHAEL C. JOHNSON Assistant U.S. Attorney 1225 Seventeenth Street, 7th Floor Denver, Colorado 80202 Telephone: (303) 454-0134 Fax: (303) 454-0408 Attorney for Defendant Anthony J. Principi

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