Free Motion to Continue - District Court of Colorado - Colorado

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

Document 150

Filed 08/31/2005

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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 No. 04-cv-00639-PSF-PAC) LILLIAN F. SANDLE, Plaintiff, v. ANTHONY J. PRINCIPI, Secretary, Department of Veterans Affairs, Defendant.

Civil Action No. 04-cv-00639-PSF-PAC (Consolidated with No. 03-cv-02435-PSF-PAC) LILLIAN F. SANDLE, Plaintiff, v. ANTHONY J. PRINCIPI, ED SANCHEZ, RAYMOND DELUNA, and E. THORSLAND, JR., Defendants.

DEFENDANTS' UNOPPOSED MOTION TO CONTINUE STATUS CONFERENCE

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

Document 150

Filed 08/31/2005

Page 2 of 4

Defendants Anthony J. Principi, Secretary, Department of Veterans Affairs, et. al., by and through undersigned counsel, hereby move to continue the status conference presently scheduled in this matter for September 16, 2005 at 10:00 a.m. In support of defendants' motion, defendants assert the following: 1. On August 5, 2005, the Court ordered a status conference set for September

16, 2005, at 10:00 a.m. See Docket No. 141. 2. Prior to the issuance of the August 5, 2005 Order, undersigned counsel for

defendants had scheduled annual leave with plans to be out of state that day. These plans included the purchase, prior to August 5, 2005, of non-refundable airline tickets. 3. In a phone conversation undersigned counsel and plaintiff had with

chambers on August 31, 2005, chambers indicated that the date of September 26, 2005 at 10:30 a.m. is currently available to the Court as a potential continued date for the status conference. Chambers also indicated that it was presently holding the date of September 26, 2005 at 10:30 a.m. as a possible date for the continued hearing, assuming the Court grants this motion. 4. Undersigned counsel contacted the plaintiff, Lillian F. Sandle, pursuant to

D.C.Colo.L.Civ.R. 7.1, to ascertain her position on this motion for a continuance, and plaintiff consents to rescheduling the status conference to September 26, 2005 at 10:30 a.m.

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

Document 150

Filed 08/31/2005

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WHEREFORE, defendants respectfully request a continuance of the status conference from September 16, 2005, at 10:00 a.m., to September 26, 2005 at 10:30 a.m. Dated this 31 st day of August, 2005. Respectfully submitted, WILLIAM J. LEONE 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 Defendants

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

Document 150

Filed 08/31/2005

Page 4 of 4

CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on August 31, 2005, I electronically filed the foregoing with the Clerk of Court using the ECF system which will send notification of such filing to the following e-mail addresses: None and I hereby certify that I have mailed or served the document or paper to the following non CM/ECF participant(s) in the manner (mail, hand delivery, etc.) indicated by the nonparticipant's name:

Ms. Lillian Sandle 2978 Cherry Street Denver, CO 80207

Thomas Kennedy, Esq. U.S. Department of Veterans Affairs Regional Counsel's Office 155 Van Gordon Street Suite 551 Lakewood, Colorado 80228

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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