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

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

Document 92

Filed 08/16/2005

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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. 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 Pretrial Order entered by the Court on

July 18, 2005, the parties were to exchange trial exhibits by July 21, 2005, with objections due by August 15, 2005. 2. The parties have been engaged in an ongoing dispute

regarding payment for trial exhibits and to date Plaintiff has not received Defendant's exhibits.

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

Document 92

Filed 08/16/2005

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3.

The parties seek to schedule a telephone conference with Plaintiff's counsel has been

the Court to resolve this matter.

advised by the Court's clerk that Magistrate Coan is out of town until August 22, 2005. Accordingly, Plaintiff seeks an extension

of time within which to file objections to Defendant's proposed trial exhibits until a telephone conference has been held and this matter has been resolved. 4. counsel Undersigned counsel has conferred with Brett C. Painter, for defendant, concerning this motion. Mr. Painter

indicates that defendant does 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 days, up to and including September 15, 2005, within which to file her objections to Defendant's proposed trial exhibits. Respectfully submitted, RONALD E. GREGSON, P.C. s/Alexandra P. Smits Ronald E. Gregson Alexandra P. Smits 1775 Sherman Street, Suite 1775 Denver, Colorado 80203 Telephone: (303) 861-2702 Facsimile: (303) 861-2706

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

Document 92

Filed 08/16/2005

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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 [email protected] CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on August 15, 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] on this ______ day of August, 2005.

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