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

Case 1:04-cv-01072-ZLW-BNB

Document 98

Filed 11/13/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-CV-01072-ZLW-BNB JOHN E. LOPEZ, Applicant, v. CARL ZENON, and KEN SALAZAR, The Attorney General of the State of Colorado, Respondents.

UNOPPOSED MOTION FOR AN EXTENSION OF TWENTY (20) DAYS TO FILE APPLICANT'S TRAVERSE

COMES NOW John E. Lopez, Applicant in the above-styled action and hereinafter referred to as "Applicant," by and through undersigned counsel, and moves this Court to enter an order permitting the undersigned counsel an additional twenty (20) days, up to and including December 4, 2006, to file his traverse in this case. In support of this motion, the Applicant states as follows: 1. Applicant's traverse is currently due to be filed on November 13, 2006 following this Court's order permitting the Applicant sixty (60) days to file a traverse in this case. 2. Undersigned counsel has recently mailed a draft of the traverse to the Applicant prior to its filing. Undersigned counsel is awaiting applicant's comments and anticipates that he will file the traverse within the twenty (20) day period as requested. 3. Undersigned counsel has contacted Ms. Hone, counsel for the respondents, who indicated that she has no objection to this motion.

Case 1:04-cv-01072-ZLW-BNB

Document 98

Filed 11/13/2006

Page 2 of 2

4. This Motion is made in good faith, and not for the purpose of delay. No prejudice could inure to any party as a result of the granting of this motion as the Applicant remains incarcerated serving a life sentence.

WHEREFORE, the Applicant respectfully requests that this Honorable Court grant his Motion to permit the undersigned counsel an additional twenty (20) days, up to and including December 4, 2006, to file his traverse in this case.

DATED this 13 day of November, 2006. Respectfully submitted, s/Robert G. Levitt Robert G. Levitt, Esq. Counsel for Applicant Colorado Reg. 24252 600 17th Street Suite 2800 South Denver, Colorado 80202 (303) 377-9000

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CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on this 13 day of November, 2006, I electronically filed the foregoing UNOPPOSED MOTION FOR AN ADDITIONAL TWENTY (20) DAYS TO FILE APPLICANT'S TRAVERSE with the Clerk of the Court using the ECF system which will send notification of such filing to the following e-mail address: [email protected] s/Robert G. Levitt Robert G. Levitt, Esq.
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