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

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

Document 208

Filed 08/01/2007

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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, WILLIAM B. HARVEY, a minor, by and through his mother Coral Creek, and LISA HARVEY, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant.

UNOPPOSED MOTION FOR EXTENSION OF TIME

COME NOW Defendant United States of America ("United States"), by and through its counsel, United States Attorney Troy A. Eid and Assistant United States Attorney Elizabeth Weishaupl, and respectfully moves this Court for an order granting a seven-day (7) extension of time to August 8, 2007, within which to file its Reply Brief in the above-captioned matter, and as grounds therefor states as follows: 1. A Reply Brief in support of Defendant's Partial Motion for Summary Judgment is due on August 1, 2007. 2. Plaintiff obtained two extensions of time to file its Response to the Motion for Summary Judgment. See Docket Number 200. 3. Undersigned counsel is unable to use computer at the U.S. Attorney's Office is undergoing "redeployment", i.e. computer replacement and

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

Document 208

Filed 08/01/2007

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undersigned counsel may not log in to any computer or have access to her files until this process is completed. 4. In addition, undersigned counsel has been preparing expert disclosures in Bethel v. United States 05-cv-01336-PSF-BNB and has been interviewing experts, compiling testimonial lists, and preparing the disclosure during the week of July 23 rd and July 30 th . 5. A seven-day extension of time will permit completion of Reply Brief and will prejudice no party. 6. Pursuant to D.C.Colo.LCivR 7.1, undersigned counsel consulted with counsel for Plaintiffs and is authorized to state that he has no objection to a seven-day extension of time within which to file a Reply Brief. WHEREFORE, undersigned counsel respectfully requests the Court to grant a seven-day (7) extension of time up to and including August 8, 2007, within which Defendant United States may file. DATED this 1st day of August, 2007.

TROY A. EID United States Attorney

s/ Elizabeth A. Weishaupl ELIZABETH A. WEISHAUPL Assistant United States Attorney 1225 Seventeenth Street, Suite 700 Denver, CO 80202 Telephone: (303) 454-0100 Fax: (303) 454-0408 E-mail: [email protected] Attorney for Defendants

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

Document 208

Filed 08/01/2007

Page 3 of 3

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on August 1, 2007, I electronically filed the foregoing with the Clerk of Court using the ECF system which will send notification of such filing to the following e-mail addresses: Kurt J. Bohn [email protected], John R. Olsen [email protected] Amanda Adams Rocque [email protected] and I hereby certify that I have mailed or served the document or paper to the following non CM/ECF participants in the manner (mail, hand delivery, etc.) indicated by the nonparticipant's name: Christopher Synsvoll, Esq. (Mail) Supervisory Attorney Federal Correctional Complex 5880 Highway 67 South P.O. Box 8500 Florence, CO 81226 Plaintiff, (Mail) William E. Harvey 11122 Concord River Court Rancho Cordova, CA 95670 s/ Dequesa Martinez Dequesa Martinez Legal Assistant to Elizabeth Weishaupl United States Attorney's Office 1225 17th Street, Suite 700 Denver, Colorado 80202