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

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

Document 95

Filed 09/13/2005

Page 1 of 3

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. SECOND 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 thirty days within which to provide objections to trial exhibits, stating as follows: 1. Pursuant to the Court's Minute Order of August 18, 2005,

Plaintiff's deadline to provide objections to Defendants' proposed trial exhibits was extended to September 15, 2005. 2. As of September 12, 2005, Plaintiff has not received

copies of Defendants' proposed exhibits. 3. Counsel for Defendants, Brett C. Painter, states that he

will likely need additional time for copying and labeling all exhibits prior to providing copies to Plaintiff.

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

Document 95

Filed 09/13/2005

Page 2 of 3

4.

Due

to

the

large

number

of

exhibits

offered

by

Defendants, Plaintiff anticipates that she will be unable to effectively review and respond to each exhibit by the current deadline of September 15, 2005. 5. Accordingly, Plaintiff seeks an extension of time within

which to file objections to Defendants' proposed trial exhibits, up to and including October 17, 2005. 6. Undersigned counsel has conferred with Brett C. Painter

concerning this motion. Mr. Painter indicates that Defendants do not oppose the motion. D.C.COLO.LCivR 7.1A. WHEREFORE, plaintiff Jennifer L. Gifford requests an extension of time in the amount of thirty-three days, up to and including October 17, 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] and

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

Document 95

Filed 09/13/2005

Page 3 of 3

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 September 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]

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