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

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

Document 101

Filed 08/22/2005

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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 MARY DEMMING ______________________________________________________________________________ COME NOW the Defendants, CMI and Kim Dempewolf, by and through counsel, and hereby submit the following Motion for Enlargement of Time to File an Answer on Behalf of Mary Demming 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. Defendant Mary Demming was served on August 1, 2004. Therefore, her Answer

is due August 22, 2005.

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

Document 101

Filed 08/22/2005

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3.

The undersigned is in the process of determining whether Ms. Demming's

insurer will retain the undersigned to represent Ms. Demming in this matter or if other counsel will be retained. The undersigned expects to know by Friday, August 26, 2005 whether or not he will represent Ms. Demming. 4. Defendants respectfully requests and enlargement of time, to and including August

29, 2005, in which to file an Answer on behalf of Ms. Demming. 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 Ms. Demming 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 Ms. Demming in this matter.

Respectfully submitted this 22nd day of August, 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 E-Mail: [email protected] E-Mail: [email protected] ATTORNEYS FOR CMI AND KIM DEMPEWOLF

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

Document 101

Filed 08/22/2005

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CERTIFICATE OF MAILING I hereby certify that on the 22nd day of August, 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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