Free Motion for Extension of Time to File Answer - District Court of Colorado - Colorado

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

Document 163

Filed 11/01/2005

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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' SECOND MOTION FOR ENLARGEMENT OF TIME TO FILE ANSWER ON BEHALF OF SANDRA CANNON-GRANT AND CHARLES ABBOTT ______________________________________________________________________________ COME NOW the Defendants, CMI, Kim Dempewolf, Marye Deming and Jason Coolidge, by and through counsel, and hereby submit the following Second Motion for Enlargement of Time to File an Answer on Behalf of Sandra Cannon-Grant and Charles Abbott. 1. Due to the difficulty of communicating with Plaintiff due to his incarceration and the

necessity of timely filing this motion, the undersigned did not confer with Plaintiff regarding the relief requested herein. 2. Defendants Sandra Cannon-Grant and Charles Abbott were served on September 28,

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

Document 163

Filed 11/01/2005

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2005. The Court granted an extension of time for these defendants to file an Answer, to and including November 1, 2005. 3. While the undersigned has a reasonable and good-faith belief that his firm will be

representing Defendants Sandra Cannon-Grant and Charles Abbott, he has not been able to get in touch with these defendants to confirm representation. 4. Defendants are contemporaneously filing a motion for the Court to release any

address information provided by Plaintiff in order that the undersigned may contact these Defendants. 5. Defendants respectfully requests an enlargement of time, to and including

November 28, 2005, in which to file an Answer on behalf of Sandra Cannon-Grant and Charles Abbott. Defendants submit that Plaintiff will not be prejudiced by granting this additional extension of time. 6. The undersigned is entering his appearance on behalf of Sandra Cannon-Grant and

Charles Abbot for the limited purpose of requesting a second request for an extension of time to file an Answer. Respectfully submitted this 1st day of November, 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 -2-

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

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Filed 11/01/2005

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CERTIFICATE OF SERVICE I hereby certify that on the 1st day of November, 2005, a true and correct copy of the foregoing was 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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