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

Case 1:00-cv-02098-REB-MJW

Document 280

Filed 12/19/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 00-cv-02098-REB-MJW KELLY FINCHER, by her guardian, JAMES FINCHER, on behalf of herself and all others similarly situated, Plaintiff, v. PRUDENTIAL PROPERTY AND CASUALTY INSURANCE COMPANY, a New Jersey Corporation, Defendant.

PLAINTIFF'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO REPLY RE PLAINTIFF'S MOTION FOR ATTORNEYS FEES Rule 7.1 Certification ­ Counsel for Plaintiff has conferred with counsel for Defendant concerning this motion, and is authorized to state that Defendant does not oppose the relief requested herein.__________________________________ Plaintiff, through counsel, for her Motion for Extension of Time to Reply Re Plaintiff's Motion for Attorneys Fees, states as follows: 1. Plaintiff's Motion for Attorneys Fees was filed on November 15,

2007, and Defendant submitted its Response on December 7, 2007. 2. Therefore, pursuant to D.C.COLO.LCivR 7.1C and REB Civ.

Practice Standard V.H.4.a, Plaintiff's Reply is currently due December 26, 2007, the day after Christmas.

Case 1:00-cv-02098-REB-MJW

Document 280

Filed 12/19/2007

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3.

The attorney primarily responsible for preparing the reply, Leif

Garrison, will be unavailable during the holidays due to long-standing family vacation plans. Co-counsel and other members of the Carey Law Firm are

unavailable to prepare the reply in his absence, as they are similarly out of town or otherwise have family vacation plans during the holidays. 4. Therefore, a brief, fifteen-day extension of time to file Plaintiff's

Reply re her Motion for Attorneys Fees, to and including January 10, 2008, is requested. 5. Neither the Court nor the parties will be prejudiced by the relief No previous extension of time has been requested, and

requested herein.

counsel for Defendant has stated that he does not oppose the requested extension of time. WHEREFORE, Plaintiff respectfully requests that this Court grant an extension of time to and including January 10, 2008, for Plaintiff to file her Reply re her Motion for Attorneys Fees.

Respectfully submitted this December 19, 2007.

s/Leif Garrison Robert B. Carey Leif Garrison The Carey Law Firm 2301 East Pikes Peak Ave. Colorado Springs, Colorado 80909 Phone: (719) 635-0377 Fax: (719) 635-2920 Email: [email protected]

Case 1:00-cv-02098-REB-MJW

Document 280

Filed 12/19/2007

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Steve W. Berman, WSBA #12536 HAGENS BERMAN, L.L.P. 1301 Fifth Avenue, Suite 2900 Seattle, WA 98101 L. Dan Rector
FRANKLIN D. AZAR & ASSOCIATES, PC

5536 Library Lane Colorado Springs, CO 80918 Attorneys for Plaintiffs

CERTIFICATE OF SERVICE I hereby certify that on this December 19, 2007, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF System, which will send notification to the following email addresses: [email protected] Additionally, a copy was mailed to the following: Kelly Fincher 436 Longleaf Ct. O'Fallon, IL 62269 s/Leif Garrison Robert B. Carey Leif Garrison The Carey Law Firm 2301 East Pikes Peak Ave. Colorado Springs, Colorado 80909 Phone: (719) 635-0377 Fax: (719) 635-2920 Email: [email protected]