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

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

Document 66

Filed 11/14/2005

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-CV-0421-MSK-OES CLAIRE D. FITZGERALD, Plaintiff, V. ALBERTO GONZALEZ, Attorney General, U.S. DEPARTMENT OF JUSTICE (FEDERAL BUREAU OF PRISONS), Defendant(s).

JOINT MOTION TO EXTEND DATE FOR FILING OF OBJECTIONS

The parties, by and through their respective counsel of record, submit the following Motion for Extension of Time to File Objections and, as grounds therefore, state as follows: 1. On October 18, 2005 the Court held a Pretrial Order Conference at which the Court entered a Final Pretrial Order. 2. Pursuant to that Order, objections to exhibits were scheduled to be submitted on or before November 4, 2005. 3. On or about November 4, 2005, the parties sought and were granted an extension to file objections to and including November 14, 2005. 4. The parties have been working in good faith to exchange and stipulate to exhibits, but given the voluminous exhibits in this matter, have been unable to complete a review. In addition, Defense counsel has recently been ill with a cold.

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

Document 66

Filed 11/14/2005

Page 2 of 2

5.

The parties ask for an extension to and including November 21, 2005 to file objections to exhibits.

6.

Counsel have discussed the relief requested with their respective clients.

WHEREFORE, the parties respectfully request that the Court extend the deadline for Filing Objections to Exhibits to and including November 21, 2005 and for such further relief as the Court deems proper. DATED this 14th day of November 2005. FOR THE PLAINTIFF: s/ Elwyn F. Schaefer Scott F. Reese 795 W. Birch Ct., Suite 100 Louisville, CO 80027 (303) 665-4448 Attorney for Plaintiff FOR THE DEFENDANT: s/ Phyllis Dow Phyllis A. Dow P.O. Box 607 Albuquerque, N.M., 87103 (505) 346-7274 Attorney for Defendant

ELWYN F. SCHAEFER & ASSOCIATES, P.C. Elwyn F. Schaefer 600 17th Street, Suite 2005-S Denver, CO 80202