Free Motion for Extension of Time to File Response/Reply - District Court of Colorado - Colorado

Case 1:04-cv-00931-LTB-MJW

Document 59

Filed 03/09/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No.: 04-CV-0093 1 -LTB-MJW ERNEST STANTON, Plaintiff, vs. YANCEY'S FOOD SERVICE CORPORATION Defendant.

MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT

Plaintiff Ernest Stanton, by and through undersigned counsel, Lindquist & Vennum P.L.L.P., respectfully submits this Motion for Extension of Time to File his Response to Defendant's Motion for Summary Judgment as follows: 1. Pursuant to D.C.Colo.LCivR 7.1(A), counsel for Plaintiff has attempted to confer

with counsel for Defendant regarding the relief sought in this Motion. At the time of the filing of this Motion undersigned counsel had not heard back from Defendant's counsel. 2. Defendant filed a Motion for Summary Judgment on February 21, 2006.

Plaintiff's response is currently due on March 13, 2006. Plaintiff respectfully requests an extension of time to file his Response to Defendant's Motion for Summary Judgment ("Response") for fourteen (14) days, up to and including March 27,2006. 3. this motion.
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Trial is not yet set in this matter and no party will be prejudiced by the granting of

Case 1:04-cv-00931-LTB-MJW

Document 59

Filed 03/09/2006

Page 2 of 3

WHEREFORE, Plaintiff respectfully requests this Court enter an order granting this motion to extend the deadline for Plaintiffs Response to Defendant's Motion for Summary Judgment up to and including March 27, 2006. Dated: March 9, 2006 T & VENNTJM

By: Is! JerA~ Jeri J. Hajtch)#33719 Lindquis~&'Veimum P.L. 600 17th St., Suite 1800-S Denver, CO 80202 (303) 573-5900 Telephone (303) 573-1956 Facsimile
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ATTORNEYS FOR PLAINTIFF

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Case 1:04-cv-00931-LTB-MJW

Document 59

Filed 03/09/2006

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on March 9, 2006 I electronically filed the foregoing MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT with the Clerk of Court using the CMIECF system which will send notification of such filing to the following email addresses: banderson(2i~stetmil.com and I hereby certify that I have served the foregoing via first class U.S. Mail on March 9, 2006 to Mr. Ernest Stanton 510 E. Monroe Drive, Unit 418 Fort Collins, CO 80525

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By: Is! Trina Moore 94jJ) 600 17th St., Suite 18~O-S Denver, CO 80202 (303) 573-5900 Telephone (303) 573-1956 Facsimi]e
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