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

Case 1:04-cv-00209-MSK-OES

Document 71

Filed 08/04/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-MK-209 (OES) PENIFER SALINAS, Plaintiff, v. DAVID CHRISTENSEN, CAPTAIN UNRUE, CHRISTOPHER "TODD" PHILLIPS, JOANIE SHOEMAKER, JOHN DOE I TO X, JOHN DOE I TO X, Defendants. DEFENDANTS UNRUH, PHILLIPS AND SHOEMAKER'S UNOPPOSED MOTION TO EXTEND DEADLINE TO FILE SETTLEMENT/DISMISSAL DOCUMENTS Defendants, Unruh, Phillips, and Shoemaker, by and through their attorneys, Hall & Evans, L.L.C., submit this Unopposed Motion to Extend Deadline to File Settlement/Dismissal Documents as follows: 1. Pursuant to this Court's Minute Order dated July 22, 2005, the parties were

advised to file Settlement/dismissal documents on or before August 5, 2005. The parties have prepared settlement documents and are in the process of circulating those documents for signature. Because there are multiple parties involved and the State of Colorado must sign off on the settlement documents, the process is taking longer than anticipated. Defendants, therefore,

Case 1:04-cv-00209-MSK-OES

Document 71

Filed 08/04/2005

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request an additional period of time, up to and including August 25, 2005, within which to file settlement/dismissal documents with this Court. 2. Pursuant to D.C.Colo.L.CivR 7.1.A, undersigned counsel has conferred with

Plaintiff's counsel who does not oppose the requested extension. 3. documents. 4. Pursuant to D.C.Colo.L.Civ.R. 6.1.D, counsel certifies that a copy of this motion This is the first extension requested for the deadline to file settlement/dismissal

for extension has been sent to all defendants, pro se parties and counsel of record. WHEREFORE, for all of the foregoing reasons, defendants respectfully request that the Court enter an Order extending the deadline to file settlement/dismissal documents for three weeks, or up to and including August 25, 2005, plus such further relief as the Court deems appropriate. Respectfully submitted this 4th day of August 2005.

Jennifer Veiga, Esq. HALL & EVANS, L.L.C. 1125 Seventeenth Street, Suite 600 Denver, Colorado 80202 303/628-3300 ATTORNEY FOR DEFENDANTS UNRUH, PHILLIPS AND SHOEMAKER

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Case 1:04-cv-00209-MSK-OES

Document 71

Filed 08/04/2005

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CERTIFICATE OF MAILING I hereby certify that on this 4th day of August 2005, I have sent a true and correct copy of the foregoing DEFENDANTS UNRUH, PHILLIPS AND SHOEMAKER'S UNOPPOSED MOTION TO EXTEND DEADLINE TO FILE SETTLEMENT/DISMISSAL DOCUMENTS via United States mail, postage prepaid, addressed to the following: Eugene G. Iredale, Esq. Julia Yoo, Esq. 105 West F. Street San Diego, CA 92101 David Christensen DOC# 118423 Kit Carson Correctional Facility 49777 County Road V Burlington, CO 80807 _______

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