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

Case 1:01-cv-02056-JLK

Document 99

Filed 12/15/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Judge John L. Kane

Civil Action No. 01-cv-2056-JLK-MJW UNITED STATES AVIATION UNDERWRITERS, INC., a New York corporation; PAUL LEADABRAND, an Idaho resident; and JEFLYN AVIATION, INC. d/b/a ACCESS AIR, an Idaho corporation, Plaintiffs, vs. PILATUS BUSINESS AIRCRAFT, LTD., a Colorado corporation; PILATUS FLUGZEUGWERKE AKTIENGESELLSCHAFT, a Swiss corporation; PILATUS AIRCRAFT, LTD., a Swiss corporation; PRATT & WHITNEY CANADA, INC., a Canadian corporation; and DOES 1 through 500, Inclusive, Defendants.

DEFENDANT PRATT & WHITNEY CANADA'S UNOPPOSED MOTION FOR EXTENSION OF TIME FOR DEFENDANTS TO FILE DAUBERT MOTIONS AND MOTIONS IN LIMINE

Defendant Pratt & Whitney Canada Corp. ("PWC"), by its attorneys, moves the Court for an extension of time within which to file their Daubert Motions, Motions in Limine, and the associated Responses and Replies pursuant to Fed.R.Civ.P. 6(b) and D.C.COLO.LCivR 6.1, and as grounds therefor states as follows: 1. Counsel for all parties concur in this Motion. Defendant PWC's attorneys have

conferred with all other counsel before filing this motion in accordance with D.C.COLO.LCivR 7.1A and were advised that all parties concur with the requested extension of time.

Case 1:01-cv-02056-JLK

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Filed 12/15/2006

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2.

Defendants request a brief extension of time within which they may file Daubert

Motions and Motions in Limine. Pursuant to the Court's Order of November 16, 2006, the deadline to file Daubert Motions is currently December 18, 2006, and the deadline to file Motions in Limine is currently December 29, 2006. Defendants request an extension to and including December 22, 2006 within which to file Daubert Motions, and an extension to and including January 5, 2007 within which to file Motions in Limine. 3. Defendants also request that the corresponding deadlines for Response and Reply

be similarly extended. Currently, the Daubert Motion Response deadline is January 8, 2007 and the Daubert Motion Reply deadline is January 18, 2007. Defendants request that these dates be extended to January 12, 2007 and January 22, 2007, respectively. 4. Defendants similarly request that the deadlines to file a Motion in Limine

Response and a Motion in Limine Reply be extended. Currently, the deadline to file a Response to a Motion in Limine is January 19, 2007 and the deadline to file a Reply to a Motion in Limine is January 29, 2007. Defendants request that these dates be changed to January 25, 2007 and February 4, 2007, respectively. 5. Defendants respectfully request this extension of time to file these motions due to

the year end holiday schedule and other business and travel requirements. 6. This is the first extension Defendants have requested within which to file Daubert

Motions, Motions in Limine, and the associated Responses and Replies. 7. Copies of this Motion have been served on PWC and all counsel of record in

accordance with D.C.COLO.LCivR 6.1.D.

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WHEREFORE, Defendant Pratt & Whitney Canada Corp. respectfully requests that the Court extend the time within which to file Daubert Motions and Motions in Limine, and the associated Responses and Replies. Respectfully submitted this 15th day of December 2006. /s/ Thomas J. Byrne Thomas J. Byrne William White BYRNE, KIELY & WHITE, L.L.P. 1120 Lincoln Street, Suite 1300 Denver, CO 80203 Telephone: (303) 861-5511 Attorneys for Defendant Pratt & Whitney Canada Corp.

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CERTIFICATE OF SERVICE

I hereby certify that on this 15th day of December 2006, I caused the foregoing DEFENDANT PRATT & WHITNEY CANADA'S UNOPPOSED MOTION FOR EXTENSION OF TIME FOR DEFENDANTS TO FILE DAUBERT MOTIONS AND MOTIONS IN LIMINE to be served by electronically filing the foregoing with the Clerk of Court using the CM/ECF system, which will send notification of such filing to the following email addresses: Jon A. Kodani, Esq. Jeffrey J. Williams, Esq. LAW OFFICES OF JON A. KODANI [email protected] Robert B. Schultz, Esq. LAW OFFICES OF ROBERT B. SCHULTZ [email protected] and by electronic mail to: Mr. Ron Ortuso PRATT & WHITNEY CANADA CORP. [email protected]

/s/ Kevin R. Kennedy

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