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

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

Document 156

Filed 10/25/2005

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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 DESIGNATE EXPERTS ______________________________________________________________________________ COME NOW the Defendants, CMI, Kim Dempewolf, Marye Deming, and Jason Coolidge, by and through their attorneys, Pryor Johnson Carney Karr Nixon, P.C., and submit Defendants' Motion for Extension of Time to Designate Experts, and state and aver as follows: CERTIFICATE OF CONFERRAL: The undersigned did not confer with Plaintiff regarding the relief requested herein due to Plaintiff's incarceration status and the necessity of timely filing this motion. 1. According to the initial Scheduling Order, Plaintiff's expert witness disclosures were

due on October 6, 2005, and Defendants' expert disclosures were due on November 6, 2005. On

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

Document 156

Filed 10/25/2005

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October 18, 2005, the Court granted Plaintiff's Motion for Extension of Time to Disclose Experts, giving Plaintiff to and including November 4, 2005 to designate expert witnesses. On October 24, 2005, the Court granted Plaintiff's Motion to Amend the Scheduling Order, and amended the Scheduling Order with respect to the discovery deadline and dispositive motions deadline. 2. As Plaintiff was granted additional time to disclose his experts, which Defendants did

not oppose, Defendants respectfully request that they be given an additional 30 days to designate their experts, to and including December 5, 2005. Respectfully submitted this 25th day of October, 2005.

s/Steven J. Wienczkowski Scott S. Nixon Steven J. Wienczkowski PRYOR JOHNSON CARNEY KARR NIXON P.C. 5619 DTC Parkway, Suite 1200 Greenwood Village, Colorado 80111 (303) 773-3500 ATTORNEYS FOR CMI, KIM DEMPEWOLF, MARYE DEMING AND JASON COOLIDGE

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

Document 156

Filed 10/25/2005

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on the 25th day of October, 2005, a true and correct copy of the foregoing was served via electronic filing, addressed to: Oloyea D. Wallin Reg. No. 111389 AVCF Arkansas Valley Correctional Facility P.O. Box 1000 Crowley, Colorado 81034 Jason Coolidge 1606 Iris Street, #62 Lakewood, Colorado 80215

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

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