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

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

Document 143

Filed 10/18/2005

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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 ENLARGEMENT OF TIME TO FILE ANSWER ON BEHALF OF SANDRA CANNON-GRANT AND CHARLES ABBOTT ______________________________________________________________________________ COME NOW the Defendants, CMI, Kim Dempewolf, and Marye Deming, by and through counsel, and hereby submit the following 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,

2005. Therefore, their Answers are due October 18, 2005.

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

Document 143

Filed 10/18/2005

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3.

The undersigned has not yet confirmed whether he will be representing Charles

Abbott and Sandra Cannon-Grant. The undersigned expects to confirm representation by October 24, 2005. 4. Defendants respectfully requests an enlargement of time, to and including

November 1, 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 brief extension of time. 5. The undersigned is entering his appearance on behalf of Sandra Cannon-Grant and

Charles Abbot for the limited purpose of requesting an extension of time to file an Answer until a determination is made as to who will be representing these defendants in this matter. Respectfully submitted this 18th day of October, 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, AND MARYE DEMING

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

Document 143

Filed 10/18/2005

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CERTIFICATE OF MAILING I hereby certify that on the 18th day of October, 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 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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