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

Case 1:04-cv-00077-WYD-PAC

Document 98

Filed 10/14/2005

Page 1 of 4

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-D-0077(PAC) JENNIFER L. GIFFORD, Plaintiff, v. FARMERS INSURANCE EXCHANGE, TRUCK INSURANCE EXCHANGE, FIRE INSURANCE EXCHANGE, MID-CENTURY INSURANCE COMPANY, and FARMERS NEW WORLD LIFE INSURANCE COMPANY, d/b/a FARMERS INSURANCE GROUP OF COMPANIES, Defendants. THIRD UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE OBJECTIONS TO TRIAL EXHIBITS Plaintiff Jennifer L. Gifford, by and through her attorneys, Ronald E. Gregson, P.C. and Mark S. Bove, P.C., moves for an extension of time in the amount of seven days within which to file objections to trial exhibits, stating as follows: 1. The undersigned certifies that he has discussed this

motion with opposing counsel, Brett C. Painter, and Mr. Painter has indicated that defendant has no objection to the motion.

D.C.COLO.LCivR 7.1A. 2. Plaintiff's counsel has now received defendants' proposed

trial exhibits, which consists of thousands of pages of documents in four file boxes. Objections to the exhibits are currently due on October 17, 2005, and plaintiff's counsel anticipates the need for several additional days to complete the objections, and requests an

Case 1:04-cv-00077-WYD-PAC

Document 98

Filed 10/14/2005

Page 2 of 4

extension of time in the amount of one week, to and including October 24, 2005. 3. There have been previous extensions of time granted for

the filing of these objections, but those were due to a dispute between the parties concerning the copying costs for the exhibits. Once that dispute was resolved in a hearing of September 2, 2005, it took some additional time for the actual copying and transmittal of the exhibits to be completed. A brief further extension of seven days will not prejudice any party. WHEREFORE, plaintiff Jennifer L. Gifford requests an extension of time in the amount of seven days, up to and including October 24, 2005, within which to file objections to defendants' proposed trial exhibits. Respectfully submitted, RONALD E. GREGSON, P.C. S/Ronald E. Gregson Ronald E. Gregson Alexandra P. Smits 1775 Sherman Street, Suite 1775 Denver, Colorado 80203 Telephone: (303) 861-2702 Facsimile: (303) 861-2706 E-mail: [email protected]

2

Case 1:04-cv-00077-WYD-PAC

Document 98

Filed 10/14/2005

Page 3 of 4

and MARK S. BOVE, P.C. s/Mark S. Bove Mark S. Bove 1775 Sherman Street, Suite 1775 Denver, Colorado 80203 Telephone: (303) 861-2702 Facsimile: (303) 861-2706 E-mail: [email protected] Attorneys for Plaintiff CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on October 13, 2005, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail address: Brett C. Painter, Esq. Davis Graham & Stubbs 1550 17th St., Suite 500 Denver, CO 80202 [email protected] S/Ronald E. Gregson Ronald E. Gregson Alexandra P. Smits Ronald E. Gregson, P.C. 1775 Sherman St., Suite 1775 Denver, Colorado 80203 Telephone: (303) 861-2702 Facsimile: (303) 861-2706 E-mail: [email protected]

3

Case 1:04-cv-00077-WYD-PAC

Document 98

Filed 10/14/2005

Page 4 of 4

CERTIFICATE OF MAILING I hereby certify that on placed a true and correct copy of the foregoing THIRD UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE OBJECTIONS TO TRIAL EXHIBITS in the U.S. Mail, with sufficient postage pre-paid, addressed to the following: Jennifer Gifford P.O. Box 27904 Denver, CO 80227 on this day of October, 2005.

4