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

Case 1:04-cv-01819-ZLW-CBS

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Filed 10/27/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Case No. 04-CV-1819-ZLW-CBS

RHONDA KYLE, Plaintiff, vs. BROWN & BIGELOW, INC. and BILL SMITH, JR., Defendants. _____________________________________________________________________ PLAINTIFF'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANTS' FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS _____________________________________________________________________

NOW COMES the plaintiff, Rhonda Kyle, by and through her attorney, Brice A. Tondre, and moves this Honorable Court for extension of time within which to respond to Defendants' First Interrogatories and Request for Production of Documents and in support thereof states: 1. Certificate of Conference. The undersigned counsel for the plaintiff has

conferred with counsel for the defendants who has authorized him to state that defendants have no objection to the relief requested in this motion. 2. During the month of October, the undersigned's schedule has precluded

him from spending the time necessary to furnish complete and accurate responses to Defendants' First Interrogatories and Request for Production of Documents.

Case 1:04-cv-01819-ZLW-CBS

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3.

Plaintiff needs a one (1) week extension of time, to and including

November 7, 2005, within which to respond to Defendants First Interrogatories and Request for Production of Documents. WHEREFORE, plaintiff prays that she be granted to and including November 7, 2005, within which to respond to Defendants' First Interrogatories and Request for Production of Documents. Respectfully submitted October 27, 2005.

s/Brice A. Tondre_________________________ Brice A. Tondre 1821 Blake Street Suite 2C Denver, Colorado 80202-1287 (303) 296-3300 (303) 296-3390 (Fax) [email protected] ATTORNEY FOR PLAINTIFF CERTIFICATE OF SERVICE I hereby certify that on October 27, 2005, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: [email protected] and I hereby certify that I have served the document or paper to the following nonCM/ECF participants by United States mail, postage prepaid, addressed to the following:

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Case 1:04-cv-01819-ZLW-CBS

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Lawrence M. Shapiro, P.A. William J. Otteson Greene Espel, PLLP 200 South 6th Street Suite 1200 Minneapolis, Minnesota 54402

s/Brice A. Tondre________________________ Brice A. Tondre

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