Free Motion for Extension of Time to File Response/Reply - District Court of Colorado - Colorado

Case 1:00-cv-02555-JLK-BNB

Document 87

Filed 06/30/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 00-cv-02555-JLK-BNB PAMELA CLIFTON, Plaintiff, v. NURSE ILONA EUBANK, in her individual capacity; OFFICER DAWN ANAYA, in her individual capacity; and OFFICER IRIA WILKS, in her individual capacity, Defendants. ______________________________________________________________________________ UNOPPOSED MOTION FOR EXTENSION OF TIME TO SUBMIT REPLY IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT ______________________________________________________________________________ Defendants, by and through counsel, Hall & Evans, L.L.C., hereby moves the Court for an extension of time up through and including July 19, 2006, in which to submit their Reply in Support of Motion for Summary Judgment, and as grounds therefore states as follows: 1. July 5, 2006. 2. 3. The Motion for Summary Judgment was initially filed on April 26, 2002. Defendants have taken no further action concerning the majority of issues raised The deadline for filing a Reply in Support of Motion for Summary Judgment is

in the Motion for Summary Judgment since that date. 4. Based on the fact that it has been nearly four years since action was taken in

regard to the remaining issues within the Motion for Summary Judgment, the undersigned is currently reviewing the file in this matter, including various deposition transcripts associated

Case 1:00-cv-02555-JLK-BNB

Document 87

Filed 06/30/2006

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with this action, and believes a short extension of time would not prejudice any party and would be beneficial for a complete understanding of the remaining issues contained in the Motion for Summary Judgment. 5. Accordingly, Defendants respectfully request a two-week extension, up to and

including July 19, 2006, to file their Reply in Support of Motion for Summary Judgment. 7. 8. This short extension of time will not prejudice Plaintiff herein. Pursuant to D.C. Colo. LR 7.1(c), a copy of this Motion for Extension of Time

has been served upon Defendants and Plaintiff, as indicated on the certificate of mailing. 9. Pursuant to D.C.Colo.LCivR 7.1(A), the undersigned has conferred with

Plaintiff's Counsel, Marcel Krzystek, Esq., concerning this Motion and was informed that Plaintiff does not oppose the Motion. WHEREFORE, Defendants respectfully request an extension of time, up to and including July 19, 2006, to file their Reply in Support of Motion for Summary Judgment in this matter. Dated this 30th day of June 2006.

Respectfully submitted,

s/ Edmund M. Kennedy_____ Edmund M. Kennedy, Esq. HALL & EVANS, L.L.C. 1125 17th Street, Suite 600 Denver, CO 80202 [email protected] Phone: 303-628-3300 Fax: 303-293-3238 ATTORNEYS FOR DEFENDANTS

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Case 1:00-cv-02555-JLK-BNB

Document 87

Filed 06/30/2006

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CERTIFICATE OF SERVICE (CM/ECF) I HEREBY CERTIFY that on this 30th day of June 2006, I electronically filed the foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME TO SUBMIT REPLY IN SUPPORT OF MOTION FOR SUMMARRY JUDGMENT with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Marcel Krzystek [email protected] [email protected] David Arthur Lane [email protected] [email protected] Mari Anne Newman [email protected] [email protected] and I hereby certify that I have mailed or served the document or paper to the following non CM/EFC participants in the manner indicated by the non-participant's name: Marsha Edney, Esq. U.S. Department of Justice Civil Division, Federal Programs Branch 20 Massachusetts Ave N.W., #7148 Washington, DC 20530 Cathie Holst Legal Services Department of Corrections 2862 South Circle Drive, Suite 400 Colorado Springs, CO 80906-4122 s/Marlene Wilson, Legal Secretary to Thomas J. Lyons, Esq. Edmund M. Kennedy Hall & Evans, L.L.C. 1125 17th Street, Suite 600 Denver, Colorado 80202-2052 303-628-3300 303-628-3368 (fax) [email protected] [email protected] ATTORNEYS FOR DEFENDANTS ILONA EUBANK, OFFICER ANAYA, and OFFICER WILKS

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