Free Motion for Extension of Time to File Answer - District Court of Colorado - Colorado

Case 1:03-cv-01095-JLK-GJR

Document 164

Filed 05/24/2007

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 03-cv-01095-JLK-GJR UNITED STATES OF AMERICA, Plaintiff, v. 60.52 ACRES OF LAND, MORE OR LESS, SITUATED IN LA PLATA COUNTY, COLORADO; and SHIRLEY ISGAR, et al., Defendants. ______________________________________________________________________________ UNOPPOSED MOTION FOR ENLARGEMENT OF TIME. ______________________________________________________________________________ Pursuant to F.R.C.P. 6(b) and D.C.COLO.LCivR. 6.1 Defendant La Plata Electric Association, Inc. ("LPEA"), through its undersigned counsel, requests an enlargement of time to and including June 29, 2007 within which to file its Answer in this matter. In support of which LPEA states as follows: 1. 2. 3. LPEA's Answer in this matter is currently due May 29, 2007. LPEA has not previously obtained an enlargement of time in this matter. LPEA and Plaintiff are engaged in settlement negotiations and anticipate that they will be able to file a stipulation and disclaimer of interest in this matter prior to May 29, 2007. 4. Pursuant to D.C.COLO.LCivR 7.1 counsel for LPEA conferred with counsel for Plaintiff who indicated that Plaintiff does not oppose this motion.

Case 1:03-cv-01095-JLK-GJR

Document 164

Filed 05/24/2007

Page 2 of 2

Respectfully submitted this 24th day of May, 2007. MAYNES, BRADFORD, SHIPPS AND SHEFTEL, LLP by:/s/ John Barlow Spear John Barlow Spear, Reg. #13878 835 East Second Avenue, Suite123 P.O. Box 2717 Durango, Colorado 81301 (970)247-1755 (970)247-8827 - facsimile [email protected] Attorney for La Plata Electric Association, Inc. CERTIFICATE OF SERVICE I hereby certify that on the 24th day of May, 2007, I electronically filed the foregoing ENTRY OF APPEARANCE with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Stephen D. Taylor, Esq. Assistant U.S. Attorney Timothy J. Monahan, Esq. Scott M. Campbell Michael A. Goldman Jannine R. Mohr Kenneth K. Skogg Malcolm M. Murray Michael P. Wilson

[email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] /s/ Suzanne P. Singley Suzanne P. Singley