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

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

Document 45

Filed 08/04/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 2004-CV-931-LTB-MJW ERNEST STANTON Plaintiff, v. YANCEY'S FOOD SERVICE CORPORATION, Defendant.

UNOPPOSED MOTION FOR EXTENSION OF TIME

Yancey's Food Service Corporation, by and through its attorneys, Bruce Anderson, Kenneth R. Stettner and Stettner, Miller and Cohn, P.C., moves for a 10 day extension of time to respond to Plaintiff's First Set of Discovery Requests and in support of this Motion, states: CERTIFICATION Counsel for Defendant has conferred in good faith with counsel for Plaintiff regarding this Motion. Plaintiff does not oppose the Motion. 1. Defendant's Responses to Plaintiff's First Set of Counsel for

Discovery Requests are due on August 4, 2005.

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

Document 45

Filed 08/04/2005

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2.

Defendant has been unable to complete its responses.

Defendant requests an additional 10 days to August 15, 2005 to respond to the requests. 3. Plaintiff has no objection to the extension of time.

WHEREFORE, Defendant Yancey's Food Service Corporation, prays for an extension of time to August 15, 2005 to respond to Plaintiff's First Set of Discovery. DATED August 4, 2005 Respectfully submitted, Stettner, Miller and Cohn, P.C.

s/Bruce Anderson Bruce Anderson Kenneth R. Stettner 1380 Lawrence Street Suite 1000 Denver, Colorado 80204 303.534.0273 303.534.5036(facsimile) e-mail: [email protected] [email protected]

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

Document 45

Filed 08/04/2005

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CERTIFICATE OF SERVICE I certify that on August 4, 2005, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: [email protected] s/Judy Romano Judy Romano Stettner, Miller and Cohn, P.C. 1050 Seventeenth Street Suite 700 Denver, Colorado 80265-2008 303.534.0273 303.534.5036(facsimile) e-mail: [email protected]

H:\BRUCE\YANCEY\STANTON\PLDS\mot.ext time 2.doc