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

Case 1:04-cv-00051-REB-CBS

Document 74

Filed 07/13/2005

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-RB-0051-REB-CBS SCOTT A. CUNNINGHAM, Plaintiff, v. BHP BILLITON PETROLEUM GREAT BRITAIN LIMITED, a United Kingdom private limited company, BHP PETROLEUM GREAT BRITAIN PLC, a United Kingdom public limited company, BHP PETROLEUM (U.K.) CORPORATION, a Delaware corporation, and HAMILTON BROTHERS PETROLEUM CORPORATION, a Delaware corporation, Defendants.

PLAINTIFF'S UNOPPOSED MOTION FOR EXTENSION OF TIME FOR THE PARTIES TO DESIGNATE EXPERT WITNESSES PURSUANT TO FED. R. CIV. P. 26(a)(2)

Plaintiff, by and through undersigned counsel, hereby submits the following Unopposed Motion for Extension of Time for the parties to designate expert witnesses pursuant to Fed. R. Civ. P. 26(a)(2). 1. motion. 2. July 15, 2005. 3. The parties require, and thus respectfully request, an extension of time, to and The current deadline for the parties to simultaneously disclose expert witnesses is Counsel for Defendants has stated he does not oppose the relief requested in this

including July 29, 2005, to make their expert disclosures.

Doc# 2037015\1

Case 1:04-cv-00051-REB-CBS

Document 74

Filed 07/13/2005

Page 2 of 3

4.

The requested extension will not affect any other case deadlines and will cause no

prejudice to any party. WHEREFORE, Plaintiff respectfully requests that the Court grant the parties additional time, to and including July 29, 2005, to file their expert witness disclosures pursuant to Fed. R. Civ. P. 26(a)(2). Dated: July 13, 2005 LINDQUIST & VENNUM P.L.L.P. By: s/ Eric B. Liebman Charles F. Brega Stuart N. Bennett Eric B. Liebman 600 17th Street, Suite 1800 South Denver, CO 80202 Telephone: 303-573-5900 Fax: 303-573-1956 [email protected] ATTORNEYS FOR PLAINTIFF

2
Doc# 2037015\1

Case 1:04-cv-00051-REB-CBS

Document 74

Filed 07/13/2005

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on July 13, 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 email addresses: [email protected] , and I certify that I have mailed the foregoing to the following non CM/ECF participants in the manner of mail indicated by the non-participant's name:

Mr. Scott Cunningham 4215 S. Dahlia Street Englewood, CO 80113-5003

LINDQUIST & VENNUM P.L.L.P. By: s/ Eric B. Liebman Charles F. Brega Stuart N. Bennett Eric B. Liebman 600 17th Street, Suite 1800 South Denver, CO 80202 Telephone: 303-573-5900 Fax: 303-573-1956 [email protected] ATTORNEYS FOR PLAINTIFF

3
Doc# 2037015\1