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

Case 1:04-cv-00188-WYD-CBS

Document 224

Filed 12/07/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO
Civil Action No. 04-cv-00188-WYD-CBS ESTATE OF WILLIAM E. HARVEY, through Administrator Joan Grace; and WILLIAM B. HARVEY, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant.

STIPULATED MOTION FOR EXTENSION OF TIME TO SUBMIT SETTLEMENT DOCUMENTS OR A MOTION TO DISMISS

The Parties, by and through undersigned counsel, hereby submit the following stipulated motion for extension of time to submit settlement documents or a motion to dismiss and state as follows: 1. The parties have resolved this case and have exchanged settlement documents. 2. The Court ordered that settlement documents or a motion to dismiss be submitted to the Court on or about December 7, 2008. 3. 4. Counsel for the Plaintiffs has been out of town. A brief seven day extension of time within which to submit a motion to dismiss in this matter will permit the obtaining of necessary signatures for the settlement documents and enable a filing of a joint motion to dismiss.

Case 1:04-cv-00188-WYD-CBS

Document 224

Filed 12/07/2007

Page 2 of 3

Wherefore, the parties respectfully request a seven day extension of time of up to and including December 14, 2007 within which to file a motion to dismiss in this matter. Dated this 7 th day of December, 2007. Respectfully Submitted, TROY A. EID United States Attorney

s/ Elizabeth A. Weishaupl Elizabeth A. Weishaupl Assistant United States Attorneys 1225 Seventeenth Street, Suite 700 Denver, CO 80202 Telephone: (303) 454-0200 Facsimile: (303) 454-0408 Email: [email protected] JOHN OLSEN

s/ John Olsen Olsen & Brown, LLC 8362 Greenwood Drive Niwot, CO 80503 Telephone: (303) 652-1551 [email protected] Attorney for the Plaintiff

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Case 1:04-cv-00188-WYD-CBS

Document 224

Filed 12/07/2007

Page 3 of 3

CERTIFICATE OF MAILING I hereby certify that on this 7th day of December, 2007, I electronically filed the foregoing Stipulated Motion for Extension of Time to Submit Settlement Documents with the Clerk of the Court using the CM/ECF system which will send notification of such filing to: John R. Olsen [email protected] Elizabeth Weishaupl [email protected] and I hereby certify that I have mailed a copy of the conventionally filed record to the following non-CM/ECF participants in the manner (mail, fax, hand delivery, etc.) indicated by the non participant's name: Agency Counsel (U.S. mail) Christopher B. Synsvoll, Esq. 5880 State Highway 67 South FCC Legal Services, P.O. Box 8500 Florence, CO 81226

s/ Dequesa Martinez Dequesa Martinez United States Attorney's Office

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