Free Motion to Amend/Correct/Modify - District Court of Colorado - Colorado

Case 1:04-cv-01295-LTB-CBS

Document 52

Filed 09/02/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO CIVIL ACTION No B CBS

BETTY GALLEGOS BERTHA PACHECO LAURA REYES MANUELA ARRAS DAVID ZUBIA ANTONIO MEZA JESUS ARENIVAR ALBA BARRIOS GLORIA CAMPOS REYNEL CARMONA SYLVIA CRUZ JESUS ESTRADA MARIA ISABEL FLORES JORGE MARTINEZ MARIA MCREYNOLD IGNACIO RANGEL JUANA ROSALES MARIA TOVAR ANTELMO ZUNUN MARIA ALVA PETRONA COREAS MARIA ESTEVEZ ALFREDO PINEDA CARMEN LUNA PATTY LEHMKUHL & LUIS OCHOA

Plaintiffs v
SWIFT & COMPANY Defendant

STIPULATED MOTION TO MODIFY SCHEDULING ORDER Plaintiffs by and through counsel BRITTON MORRELL of THE MORRELL LAW OFFICE move to modify the Scheduling Order and as grounds state as follows:

The parties through respective counsel have conferred regarding this motion and are in agreement with this Motion The parties anticipate between to depositions in this action The

depositions were scheduled to occur after the settlement conference in an effort to avoid litigation costs in the event of a successful resolution As the settlement conference did not resolve the claims the depositions have proceeded however the parties are unable to

Case 1:04-cv-01295-LTB-CBS

Document 52

Filed 09/02/2005

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schedule the depositions to occur before the current discovery deadline of November The parties propose modifying the Scheduling Order as follows: a Discovery Cut Off FROM November TO February TO April

b Dispositive Motion Deadline FROM February

Good cause is alleged as follows: a This Civil Action has plaintiffs all but three speak very little

English The depositions therefore take longer to finish b The trial date set for August and September of affected c The depositions in the number contemplated have been will not be

exceedingly difficult to schedule given the need to coordinate four calendars interpreter d The parties held off on depositions until initial written discovery had been served and answered and the parties were given an opportunity to meet and confer regarding settlement Respectfully submitted this September THE MORRELL LAW OFFICE LLC S Britton Morrell Britton Morrell Esq THE MORRELL LAW OFFICE th Street Greeley CO FAX E mail:mloffice@mac com Attorney for Plaintiffs plaintiff Defense Counsel Plaintiffs Counsel and

Case 1:04-cv-01295-LTB-CBS

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Filed 09/02/2005

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CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing document has been sent to counsel of record on this APRIL ECF to:

W V Bernie Siebert Esq Stuart B Johnston Jr ORIGINAL TO: SHERMAN & HOWARD VINSON & ELKINS LLP LLC Trammell Crow US District Court th th Street Ste Center Street Room A Denver Colorado Ross Avenue Dallas Texas Alfred A Arraj U S Courthouse Denver Colorado

COPY TO ALL CLIENTS S Brandy Gutierrez BRANDY GUTIERREZ