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

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

Document 187

Filed 11/22/2005

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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 FILE POST-TRIAL MOTIONS

Defendant, J.E.H. Knutson, by and through his attorneys, Fairfield and Woods, P.C., respectfully states as follows: 1. On November 14, 2005, the Chief Deputy Clerk in the United

States District Court for the District of Court entered Judgment against Defendant. Pursuant to F.R.C.P. 59, Defendant'deadline to seek post-trial relief is Friday, s November 24, 2005. In addition to time constraints resulting from the Thanksgiving holiday, Defendant desires additional time to further consider whether to request relief pursuant to F.R.C.P. 59. 2. As evidenced by the agreement of counsel, the parties recognize

allowing Defendant to and including Monday, December 5, 2005 in which to seek posttrial relief will not be prejudicial.

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

Document 187

Filed 11/22/2005

Page 2 of 3

3.

Pursuant to D.C.Colo.LCiv R7.1(A), on November 22, 2005,

counsel conferred regarding this request. Specifically, during a telephone conversation on that date, Plaintiff'counsel, Richard F. Gottlieb, advised Plaintiff does not oppose s Defendant being permitted an additional period of time to and including Monday, December 5, 2005 in which to file post-trial motions. Conversely, the undersigned agreed to permit Plaintiff a similar additional period of time in which to claim attorney fees and costs. Counsel agree extending these deadlines is reasonable and necessary, in part, because of the Thanksgiving holiday. WHEREFORE, Defendant respectfully requests the Court enter an Order permitting him an additional period of time to and including Monday, December 5, 2005 in which to seek post-trial relief at the trial court level. Respectfully submitted this 22nd day of November 2005.

s/ Michael R. McCurdy 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

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

Document 187

Filed 11/22/2005

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 22nd day of November 2005 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/ Michael R. McCurdy 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] ATTORNEYS FOR DEFENDANT

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