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

Case 1:03-cv-01973-PSF-MJW

Document 236

Filed 10/13/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-CV-01973-PSF-MJW (Consolidated with 04-CV-02112-PSF-MJW) WALKER GROUP, INC., Plaintiff, v. FIRST LAYER COMMUNICATIONS, INC. and J.E.H. KNUTSON, Defendants.

UNOPPOSED MOTION FOR ADDITIONAL TIME TO COMPLY WITH ATTORNEY FEES AWARD

Defendant, J.E.H. Knutson, by and through counsel, Fairfield and Woods, P.C., respectfully states as follows: 1. Pursuant to D.C. Colo. L. Civ. R. 7.1, the parties conferred about the

subject matter of this Unopposed Motion during an October 12, 2006 telephone conversation. Specifically, Defendant'counsel, Michael R. McCurdy, spoke with Plaintiff'counsel, Richard s s Gottlieb. After reminding Plaintiff that Defendant lacks assets necessary to satisfy the attorney fees award, counsel agreed to extend Defendant'October 13, 2006 payment deadline to and s including Friday, October 20, 2006. In the interim, Plaintiff agreed to advise Defendant whether and when it will pursue payment of the attorney fees awarded it on September 29, 2006.

Case 1:03-cv-01973-PSF-MJW

Document 236

Filed 10/13/2006

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2.

As evidenced by the agreement of counsel, good cause exists to extend the

October 13, 2006 deadline to and including October 20, 2006. 3. For the Court'convenience a proposed Order is submitted. s

WHEREFORE, Defendant respectfully requests the Court to enter an Order extending the October 13, 2006 deadline established in its September 19, 2006 Order to and including Friday, October 20, 2006. Respectfully submitted this 13th day of October 2006.

s/ Colin A. Walker Michael R. McCurdy Colin A. Walker Fairfield and Woods, P.C. 1700 Lincoln Street, Suite 2400 Denver, CO 80203 Phone: (303) 830-2400 Fax: (303) 830-1033 Email: [email protected] Email: [email protected] ATTORNEYS FOR DEFENDANT J.E.H. KNUTSON

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Case 1:03-cv-01973-PSF-MJW

Document 236

Filed 10/13/2006

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CERTIFICATE OF SERVICE I hereby certify that on this 13th day of October 2006, I electronically filed the foregoing with the Court using the CM/ECF system, which will send notification of such filing to the following email-addresses: [email protected] [email protected] s/ Colin A. Walker Michael R. McCurdy Fairfield and Woods, P.C. 1700 Lincoln Street, Suite 2400 Denver, CO 80203 Phone: (303) 830-2400 Fax: (303) 830-1033 Email: [email protected] Email: [email protected] ATTORNEYS FOR DEFENDANT J.E.H. KNUTSON

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