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

Case 1:03-cv-02319-WDM-MJW

Document 200

Filed 12/27/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No.: 03-CV-02319-WDM-MJW OLOYEA D. WALLIN, Plaintiff, vs. CMI, KIM DEMPEWOLF, RYAN BRADLEY, MARY, SANDRA, AARON, JASON and CHARLES Defendants. ______________________________________________________________________________ DEFENDANTS' MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S DISCOVERY REQUESTS ______________________________________________________________________________ COME NOW the Defendants, CMI, Kim Dempewolf, Marye Deming and Jason Coolidge, by and through counsel, and hereby submit the following Motion for Extension of Time to Respond to Plaintiff's Discovery Requests: 1. Due to the difficulty of telephonically communicating with Plaintiff due to his

incarceration and the necessity of timely filing this motion, the undersigned did not confer with Plaintiff pursuant to D.C. COLO.LCivR. 7.1(A) regarding the relief requested herein.

Case 1:03-cv-02319-WDM-MJW

Document 200

Filed 12/27/2005

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2.

On December 2, 2005, Defendants received numerous discovery requests

propounded by Plaintiff dated November 25, 2005. Defendants' responses to Plaintiff's discovery are due December 28, 2005. 3. While Defendants are in the process of completing their discovery responses, due to

the holiday season and the difficulty of conferring with the undersigned regarding their responses, Defendants request additional time to provide responses to Plaintiff's discovery. Defendants request an additional fourteen (14) days, to and including January 11, 2006, to provide their responses. 4. Defendants submit that Plaintiff will not be prejudiced by this brief extension of

time. Defendants also note that, pursuant to the Court's Minute Order dated September 6, 2005, Plaintiff was granted an extension of thirty (30) days to respond to Defendants' discovery requests. 5. This is the first request by Defendants for an extension of time to respond to

Plaintiff's discovery.

Respectfully submitted this 27th day of December, 2005. s/ Steven J. Wienczkowski Steven J. Wienczkowski PRYOR JOHNSON CARNEY KARR NIXON , P.C. 5619 DTC Parkway, Suite 1200 Greenwood Village, Colorado 80111 (303) 773-3500 E-Mail: [email protected] ATTORNEYS FOR CMI, KIM DEMPEWOLF, MARYE DEMING AND JASON COOLIDGE

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Case 1:03-cv-02319-WDM-MJW

Document 200

Filed 12/27/2005

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CERTIFICATE OF SERVICE I hereby certify that on the 27th day of December, 2005, a true and correct copy of the foregoing was filed via electronic filing, as well as placed in the U.S. Mail, postage prepaid thereon, addressed to: Oloyea D. Wallin Reg. #111389 Arkansas Valley Correctional Facility P.O. Box 1000 Crowley, Colorado 81034

s/Laura Buckingham Laura Buckingham, on behalf of Pryor Johnson Carney Karr Nixon, P.C.

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