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

Case 1:04-cv-01332-REB-OES

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Filed 07/11/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-1332-REB-OES DR. WILLIAM ZITTERKOPF, Plaintiff, v. CHEYENNE COUNTY SCHOOL DISTRICT RE-5, BOARD OF EDUCATION, CHEYENNE COUNTY SCHOOL DISTRICT RE-5, MONICA WENDT, in her individual capacity, and FLOYD BEARD, in his individual capacity, Defendants. _______________________________________________________________________________ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE STIPULATION FOR DISMISSAL WITH PREJUDICE _______________________________________________________________________________ Defendants, CHEYENNE COUNTY SCHOOL DISTRICT RE-5, BOARD OF EDUCATION, CHEYENNE COUNTY SCHOOL DISTRICT RE-5, MONICA WENDT, in her individual capacity, and FLOYD BEARD, in his individual capacity, by their attorneys, SONJA S. MCKENZIE and WENDY J. SHEA of SENTER, GOLDFARB & RICE, L.L.C., hereby file this Unopposed Motion for Extension of Time to File Stipulation for Dismissal. IN SUPPORT THEREOF, Defendants state as follows: 1. A stipulation for the dismissal of Plaintiff's claims against Defendants is currently

due on July 11, 2005. 2. However, the parties are in the process of finalizing the settlement in this case,

including the exchange of settlement proceeds. Therefore, the parties require additional time to file

Case 1:04-cv-01332-REB-OES

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Filed 07/11/2005

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a stipulation for dismissal. The parties will endeavor to complete the settlement by July 15, 2005. Accordingly, Defendants request an extension of time up to and including July 15, 2005 in which to file a stipulation for dismissal regarding Plaintiff's claims. 3. Pursuant to D.C.Colo.L.Civ.R. 7.1(A), counsel for Defendants conferred with

Plaintiff's counsel, Joan M. Bechtold, regarding the relief sought in this motion. Ms. Bechtold indicated that she was not opposed to the requested extension of time. WHEREFORE, for the reasons stated herein, Defendants respectfully request that this Court grant an extension of time up to and including July 15, 2005 in which to file a stipulation for dismissal of Plaintiff's claims against Defendants.

Respectfully submitted, SENTER GOLDFARB & RICE, L.L.C.

By: s/ Sonja S. McKenzie Sonja S. McKenzie Wendy J. Shea 1700 Broadway, Suite 1700 Denver, CO 80290 Telephone: (303) 320-0509 Facsimile: (303) 320-0210 Attorneys for Defendants

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Case 1:04-cv-01332-REB-OES

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Filed 07/11/2005

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CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 11th day of July, 2005, a true and correct copy of the above and foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE STIPULATION FOR DISMISSAL WITH PREJUDICE was filed with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following email addresses: [email protected] [email protected]

s/ Barbara A. Ortell

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