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

Case 1:04-cv-00421-MSK-PAC

Document 86

Filed 02/21/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-00421-MSK-PAC CLAIRE FITZGERALD, Plaintiff(s), vs. ALBERTO R. GONZALES, Attorney General, U.S. Department of Justice (Federal Bureau of Prisons), Defendant(s).

STIPULATED MOTION FOR EXTENSION OF TIME TO FILE JOINT PROPOSED JURY INSTRUCTIONS AND JOINT VERDICT FORM

COMES NOW DEFENDANT ALBERTO R. GONZALES, by and through undersigned counsel of record, and respectfully requests the Court for an Order extending the time in which to file the Joint Proposed Jury Instructions and Joint Verdict Form to and including February 23, 2006. As grounds therefore, he would show

the Court that counsel have completed the Joint Exhibit List, the Joint Witness List, the Joint Proposed Voir Dire, and the Joint Glossary, which will be filed today. Counsel are still

conferring on the Joint Proposed Jury Instructions and the Joint Verdict Form and will be filing same as of February 23, 2006. Counsel for Plaintiff concurs in this Motion. Order is submitted herewith. Therefore, an

Case 1:04-cv-00421-MSK-PAC

Document 86

Filed 02/21/2006

Page 2 of 2

Respectfully submitted, DAVID C. IGLESIAS United States Attorney s/Phyllis A. Dow PHYLLIS A. DOW Special Attorney District of Colorado Assistant U.S. Attorney P.O. Box 607 Albuquerque, New Mexico 87103 Telephone: (505) 346-7274 FAX: (505) 346-7205 E-mail: [email protected] Attorney for Defendant I HEREBY CERTIFY that on February 21, 2006, I electronically filed with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Scott Frederick Reese [email protected] Elwyn F. Schaefer [email protected], and I hereby certify that I have mailed or served the document to the following participants via First Class Mail to: Scot L. Gulick Federal Bureau of Prisons Tower II, 8th Floor 400 State Avenue Kansas City, Kansas 66101-2421 s/Phyllis A. Dow PHYLLIS A. DOW Special Attorney District of Colorado Assistant U.S. Attorney P.O. Box 607 Albuquerque, New Mexico 87103 Telephone: (505) 346-7274 FAX: (505) 346-7205 E-mail: [email protected] Attorney for Defendant
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