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

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

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Filed 08/05/2005

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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. _____________________________________________________________________ MOTION FOR EXTENSION OF TIME TO MAKE INITIAL DISCLOSURES _____________________________________________________________________

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 make mandatory disclosures pursuant to Rule 26(a)(1) F.R.C.P. In support thereof, plaintiff states: 1. Certificate of Conference. The undersigned has conferred with counsel

for the defendants who has authorized him to state that defendants have no objection to the relief sought in this motion on the condition that they be granted a similar extension. 2. The undersigned a response to a motion for summary judgment due on

August 8, 2005. This response is of inordinate complexity and has consumed considerably more time than anticipated. 3. The undersigned must be out of town for depositions on August 8, 2005.

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

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4.

Because of the foregoing, the undersigned has been unable to complete

the work necessary to make meaningful Rule 26(a)(1) disclosures by August 8, 2005, the present deadline. 5. Plaintiff needs a two (2) day extension of time within which to make said

disclosures. Defendants likewise request a two (2) day extension. WHEREFORE, plaintiff prays that she be granted to and including August 10, 2005, within which to make her disclosures pursuant to Rule 26(a)(1) F.R.C.P. Respectfully submitted this 5th day of August, 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 August 5, 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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