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

Case 1:01-cv-02056-JLK

Document 238

Filed 08/20/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Judge John L. Kane

Civil Action No. 01-cv-2056-JLK-MJW UNITED STATES AVIATION UNDERWRITERS, INC., a New York corporation; PAUL LEADABRAND, an Idaho resident; and JEFLYN AVIATION, INC. d/b/a ACCESS AIR, an Idaho corporation, Plaintiffs, vs. PILATUS BUSINESS AIRCRAFT, LTD., a Colorado corporation; PILATUS FLUGZEUGWERKE AKTIENGESELLSCHAFT, a Swiss corporation; PILATUS AIRCRAFT, LTD., a Swiss corporation; PRATT & WHITNEY CANADA, INC., a Canadian corporation; and DOES 1 through 500, Inclusive, Defendants.

DEFENDANT PRATT & WHITNEY CANADA'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY TO PLAINTIFFS' RESPONSE TO MOTION FOR JUDGMENT AS A MATTER OF LAW OR FOR NEW TRIAL

Defendant Pratt & Whitney Canada Corp. ("PWC"), by its attorneys, respectfully moves the Court pursuant to Fed.R.Civ.P. 6(b) and D.C.COLO.LCivR 6.1 for an extension of time of eight days within which to file its Reply to Plaintiffs' Response to Motion for Judgment as a Matter of Law or for New Trial (Doc. 235) by eight days, to and including August 28, 2007, and as grounds therefor states as follows: 1. PWC's attorneys have conferred with Plaintiffs' attorneys before filing this

motion in accordance with D.C.COLO.LCivR 7.1A and were advised that Plaintiffs do not object to the requested extension of time.

Case 1:01-cv-02056-JLK

Document 238

Filed 08/20/2007

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2.

PWC's Reply to Plaintiffs' Response to Motion for Judgment as a Matter of Law

or for New Trial ("PWC's Reply") is due today, August 20, 2007. 3. PWC respectfully requests an extension of time within which to complete its

analysis of issues raised by Plaintiffs and file its Reply due to travel commitments of counsel and unanticipated business matters. 4. 5. This is the first extension of time to file its Reply that PWC has requested. Copies of this Motion will be served on PWC and all counsel of record in

accordance with D.C.COLO.LCivR 6.1.D. WHEREFORE, Defendant Pratt & Whitney Canada Corp. respectfully requests that the Court extend the time within which to file its Reply to Plaintiffs' Response to Motion for Judgment as a Matter of Law or for New Trial by eight days, to and including August 28, 2007. Respectfully submitted this 20th day of August 2007. s/ Thomas J. Byrne Thomas J. Byrne William White BYRNE, KIELY & WHITE, L.L.P. 1120 Lincoln Street, Suite 1300 Denver, Colorado 80203 Telephone: (303) 861-5511 E-mail: [email protected]

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Case 1:01-cv-02056-JLK

Document 238

Filed 08/20/2007

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CERTIFICATE OF SERVICE I hereby certify that on this 20th day of August 2007 I caused the foregoing DEFENDANT PRATT & WHITNEY CANADA'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY TO PLAINTIFFS' RESPONSE TO MOTION FOR JUDGMENT AS A MATTER OF LAW OR FOR NEW TRIAL to be served by electronically filing the foregoing with the Clerk of Court using the CM/ECF system, which will send notification of such filing to the following e-mail addresses: Jon A. Kodani, Esq. Jeffrey J. Williams, Esq. LAW OFFICES OF JON A. KODANI [email protected] and by electronic mail to: Mr. Ron Ortuso PRATT & WHITNEY CANADA CORP. [email protected] Robert B. Schultz, Esq. LAW OFFICES OF ROBERT B. SCHULTZ [email protected]

s/ Kevin R. Kennedy

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