Free Motion to Reset - District Court of Colorado - Colorado

Case 1:04-cv-01185-WDM-PAC

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Filed 01/18/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-CV-1185-WDM-PAC GREG FELDMAN, Plaintiff, v. JOBSON PUBLISHING, LLC, a Delaware Corporation, POSTGRADUATE INSTITUTE FOR MEDICINE, INC., a member of the Jobson Education Group, a Delaware corporation, INTERNATIONAL CENTER FOR POSTGRADUATE MEDICAL EDUCATION, a member of the Jobson Education Group, a Delaware corporation, Defendants.

DEFENDANTS' UNOPPOSED MOTION TO RE-SCHEDULE SETTLEMENT CONFERENCE

Defendants Jobson Publishing L.L.C. and Postgraduate Institute for Medicine, Inc. (collectively, "Defendants"), by and through counsel, Hall & Evans, L.L.C., hereby submit this Unopposed Motion to Re-schedule Settlement Conference, as follows: 1. Pursuant to the Scheduling Order entered by this Court on November 15, 2005, a

settlement conference is currently scheduled in this matter on February 13, 2006 at 1:30 p.m. before Magistrate Judge Coan. 2. Counsel for Defendants recently learned that their client representative will be

unable to attend the settlement conference on February 13. Counsel therefore contacted the Court Clerk for Magistrate Judge Coan and requested alternative dates for a re-scheduled

Case 1:04-cv-01185-WDM-PAC

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settlement conference. After conferring with Defendants' client representative and counsel for Plaintiff, it was determined that one of the dates offered by the Court Clerk, March 8, 2006 at 3:00 p.m., would work for all parties. 3. On January 6, 2006, Plaintiff filed a Motion for Leave to File Second Amended

Complaint, seeking to change the named Defendants in this matter and to add a new state law claim for outrageous conduct. On January 17, 2006, Plaintiff filed an Unopposed Motion to Stay Discovery, requesting that all discovery in this matter be stayed until five days after this Court rules on his Motion for Leave to File Second Amended Complaint. At this time, it is unclear when Plaintiff's request to amend will be ruled on or when discovery will commence, providing an additional reason for delaying the settlement conference. 4. Pursuant to D.C.Colo.L.Civ.R. 7.1(A), the undersigned counsel conferred with

counsel for Plaintiff prior to filing this Motion. Plaintiff does not oppose this Motion, and has confirmed that the March 8, 2006 date proposed by Defendants is acceptable to him. WHEREFORE, Defendants Jobson Publishing L.L.C. and Postgraduate Institute for Medicine, Inc. respectfully request that this Court cancel the settlement conference currently scheduled for February 13, 2006 at 1:30 p.m., and re-schedule the settlement conference for March 8, 2006 at 3:00 p.m.

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Dated this 18th day of January, 2006. Respectfully submitted,

s/ Gillian Dale . Thomas J. Lyons, Esq. Gillian Dale, Esq. Attorneys for Defendants Hall & Evans, L.L.C. 1125 17th Street, Suite 600 Denver, CO 80202-2052 (303) 628-3300 phone (303) 628-3368 fax [email protected] [email protected]

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Case 1:04-cv-01185-WDM-PAC

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CERTIFICATE OF MAILING I hereby certify that on the 18th day of January, 2006, I served a true and correct copy of the foregoing DEFENDANTS' UNOPPOSED MOTION TO RE-SCHEDULE SETTLEMENT CONFERENCE with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail address: Julie M. Schmidt Ari Krichiver Nantiya Ruan Laura L. Rovner Student Law Office University of Denver Sturm College of Law 2255 E. Evans Avenue Denver, CO 80208 [email protected] [email protected]

s/ Denise Gutierrez . Thomas J. Lyons, Esq. Gillian Dale, Esq. Attorneys for Defendants Hall & Evans, L.L.C. 1125 17th Street, Suite 600 Denver, CO 80202-2052 (303) 628-3300 phone (303) 628-3368 fax [email protected] [email protected]

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