Free Motion to Stay - District Court of Colorado - Colorado

Case 1:04-cv-00208-PSF-CBS

Document 52

Filed 07/18/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-0208-PSF-CBS GEORGE WHITE, Plaintiff, vs. WATERPIK TECHNOLOGIES, Defendant. U NOPPOSED M OTION TO S TAY B RIEFING AND R ULING ON S UMMARY J UDGMENT Defendant Water Pik Technologies, through its counsel, Holland & Hart, LLP, hereby respectfully requests that the Court stay any further briefing or the entry of any order regarding Water Pik's Motion for Summary Judgment, and as grounds therefore state as follows: 1. case. 2. Unfortunately, Mr. White is unavailable to review or execute a Settlement The parties have reached an agreement concerning the resolution of this

Agreement and Release for the next two weeks. 3. The parties will endeavor to submit a Stipulated Motion to Dismiss on or

before August 15, 2005. 4. Counsel for Plaintiff was unavailable to sign this pleading in the form of a

stipulation, so it has been filed as an unopposed motion instead. 5. No party will be prejudiced by the granting of this Motion.

Case 1:04-cv-00208-PSF-CBS

Document 52

Filed 07/18/2005

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WHEREFORE, Water Pik requests that the Court enter an Order staying further briefing or ruling on Water Pik's Motion for Summary Judgment pending the filing of a Motion to Dismiss. Dated July 18, 2005.

s/Alan D. Schuchman Alan D. Schuchman H OLLAND & H ART LLP 8390 East Crescent Parkway, Suite 400 Greenwood Village, Colorado 80111-2800 (303) 290-1600 (303) 290-1606 John M. Husband, P.C. HOLLAND & HART LLP 555 Seventeenth Street, Suite 3200 Denver, Colorado 80201-8749 (303) 295-8000 A TTORNEYS FOR W ATER P IK T ECHNOLOGIES , I NC .

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Case 1:04-cv-00208-PSF-CBS

Document 52

Filed 07/18/2005

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CERTIFICATE OF SERVICE I certify that on July 18, 2005 I served a copy of the foregoing document to the following by: U.S. Mail, postage prepaid Hand Delivery Fax David A. Lane, Esq. Killmer & Lane LLP 1543 Champa Street, Suite 400 Denver, Colorado 80202 Richard Tipton Vice President, General Counsel and Secretary Water Pik Technologies, Inc. 23 Corporate Plaza, Suite 246 Newport Beach, CA 92660

s/Alan D. Schuchman

3404857_2.DOC

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