Free Motion for Extension of Time to File Response/Reply - District Court of Colorado - Colorado

Case 1:03-cv-02320-PSF-MJW

Document 66

Filed 11/15/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-02320-PSF-MJW MARK JORDAN, Plaintiff, v. ROBERT A. HOOD, Warden, ADX Florence, MARY H. SOSA, Acting ISM, ADX Florence, in their official capacities, and FEDERAL BUREAU OF PRISONS, Defendants.

UNOPPOSED MOTION FOR EXTENSION OF TIME

Defendants Robert A. Hood and Mary Sosa, in their official capacities, and the Federal Bureau of Prisons (BOP), move that the time for responding to Plaintiff's Partial Motion for Summary Judgment be extended from November 15, 2005 to November 23, 2005. In support the Defendants state as follows: 1. Plaintiff filed a Partial Motion for Summary Judgment on October 20, 2005. Defendants' response is due on November 15, 2005. 2. Since the date of the filing of the Motion for Partial Summary Judgment, undersigned counsel has been preparing for a jury trial in the case, Crowle v. Norton, 04cv-00982-PSF-BNB, which trial commenced on November 14, 2005. Therefore, counsel

Case 1:03-cv-02320-PSF-MJW

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Filed 11/15/2005

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has been unable to prepare a response to the Partial Motion for Summary Judgment, and additional time is needed. 3. Pursuant to D.C.COLO.LCivR. 7.1A, the undersigned has contacted Plaintiff's counsel regarding this motion, and Mr. Ramey indicated that he had no objection. Dated this 15th day of November, 2005. Respectfully submitted, WILLIAM J. LEONE United States Attorney

/s/ William G. Pharo By: William G. Pharo Assistant United States Attorney 1225 Seventeenth St., Suite 700 Denver, Colorado 80202 Telephone: (303) 454-0100 Fax: (303) 454-0407 Email: [email protected] Attorney for Defendants

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Case 1:03-cv-02320-PSF-MJW

Document 66

Filed 11/15/2005

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CERTIFICATE OF SERVICE I hereby certify that on November 15, 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 -mail addresses: Edward T. Ramey [email protected] [email protected] and I hereby certify that I have mailed or served the document or paper to the following non CM/ECF participants in the manner indicated by the nonparticipant's name: By mail, postage prepaid Theresa Montoya Englewood - FCI 9595 West Quincy Avenue Littleton, CO 80123

s/ William G. Pharo William G. Pharo, AUSA Attorney for Defendants United States Attorney's Office 1225 Seventeenth Street, Suite 700 Denver, CO 80202 Phone: 303-454-0100 Fax: 303-454-0407 [email protected]

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