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

Case 1:04-cv-01140-RPM

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Filed 07/08/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04- cv- 1140- RPM-PAC STEPHANIE J. MARTIN, Plaintiff, vs. HARTFORD LIFE AND ACCIDENT INSURANCE COMPANY, INC., Defendant. ________________________________________________ ________________________ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE DISMISSAL PAPERS ________________________________________________________________________ Defendant Hartford Life and Accident Insurance Company, Inc., by its counsel, hereby moves the Court for a five (5) day extension of time to file dismissal papers in this matter and as grounds therefore, states as follows: 1. On June 21, 2005, a Joint Notice and Request to Vacate Trial was filed in

this matter insofar as the parties had reached a settlement. 2. By Minute Order entered on June 23, 2005, the Court vacated the trial

date and directed that a stipulated motion to dismiss be filed by July 8, 2005. 3. Although Plaintiff and her counsel have signed the settlement agreement,

the representative of Hartford who must sign on behalf of defendant is unavailable until Tuesday July 12. Wherefore, the parties request that the Court extend the time to file dismissal papers in this action until and including July 13, 2005.

Case 1:04-cv-01140-RPM

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Filed 07/08/2005

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Date: July 8, 2005. Respectfully submitted, s/Gregory A. Eurich Gregory A. Eurich HOLLAND & HART LLP 555 ­ 17th Street, Suite 3200 P. O. Box 8749 Denver, CO 80202 (303) 295-8166 Fax: No. (303) 975-5464 [email protected] ATTORNEYS FOR DEFENDANT HARTFORD LIFE AND ACCIDENT INSURANCE COMPANY, INC.

Case 1:04-cv-01140-RPM

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Filed 07/08/2005

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CERTIFICATE OF SERVICE

I hereby certify that on July 8, 2005, I electronically filed the foregoing with the Clerk of the 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 electronically sent a copy of the foregoing to the following non CM/ECF participants via e- mail: [email protected] [email protected]

s/Gregory A. Eurich Gregory A. Eurich Holland & Hart LLP 555 ­ 17th Street, Suite 3200 P. O. Box 8749 Denver, CO 80202 (303) 295-8166; (303) 295- 8584 Fax: No. (303) 975-5464 [email protected]

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