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

Case 1:03-cv-02073-WDM-KLM

Document 227

Filed 01/03/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 1:03-cv-2073-WDM-PAC ROBERTA PULSE, TONYA HOUSE, Plaintiffs v. THE LARRY H. MILLER GROUP, Defendant

DEFENDANT'S UNOPPOSED MOTION FOR FOUR-HOUR EXTENSION OF TIME TO FILE JURY INSTRUCTIONS

Pursuant to D.C.COLO.LCiv.R. 6.1B, Defendant, by and through its counsel, Holland & Hart, LLP, and Judith Holmes & Associates, LLC, respectfully requests that the Court grant the Parties a brief, four-hour extension of time in which to file a joint proposed set of jury instructions. In further support of the Motion, Defendant states as follows: 1. The Parties' joint set of jury instructions was due on January 3, 2006 at 1:00 p.m. 2. During the past week, the Parties have been diligently working to compile a single proposed set of jury instructions and objections that conform to the Court's trial procedures memorandum, as well as other submissions that are necessary for the upcoming Trial Preparation Conference on Thursday, January 4.

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Case 1:03-cv-02073-WDM-KLM

Document 227

Filed 01/03/2006

Page 2 of 4

3. Due to the press of completing submissions, however, the undersigned was unable to complete several instructions and confer with opposing counsel to finalize a joint submission of proposed jury instructions. 4. In the meantime, Plaintiffs submitted their own set of jury instructions that do not conform to the Court's trial procedures memorandum. 5. Defendant seeks a brief 4-hour extension of time in which the Parties may finalize and jointly submit a single proposed set of jury instructions (with objections) that conforms to the Court's procedures. 6. D.C.COLO.LCivR. 7.1A Certification: Before noon today, undersigned counsel contacted opposing counsel to confer about Plaintiffs' position concerning this Motion. At 12:06 pm, Plaintiffs' counsel communicated that Plaintiffs' had no objection to the granting of this Motion. 7. D.C.COLO.LCivR 7.1D Certification: The undersigned has provided a copy of this Motion to Defendant.

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Case 1:03-cv-02073-WDM-KLM

Document 227

Filed 01/03/2006

Page 3 of 4

WHEREFORE, Defendant respectfully requests that this Court enter an Order in the form attached to provide Defendant with an additional four (4) hours in which to file the joint set of proposed jury instructions (and objections). DATED: January 3, 2006. s/ Christopher M. Leh Christopher M. Leh HOLLAND & HART LLP 1800 Broadway, Suite 300 Boulder, CO 80302 Telephone: 303-473-2700 Fax: 303-473-2720 E-mail: [email protected] Steven M. Gutierrez HOLLAND & HART LLP 555 Seventeenth St., Suite 3200 Denver, CO 80202 Telephone: 303-295-8000 Fax: 303-295-8261 E-mail: [email protected] Judith Holmes JUDITH HOLMES & ASSOCIATES, LLC 7887 E. Belleview Suite 1100 Englewood, CO 80111 Telephone: 303-228-2267 Facsimile: 303-781-6877 Email: [email protected] ATTORNEYS FOR DEFENDANT

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Case 1:03-cv-02073-WDM-KLM

Document 227

Filed 01/03/2006

Page 4 of 4

CERTIFICATE OF SERVICE

I hereby certify that on January 3, 2006, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Kimberlie K. Ryan, [email protected] Whitney Traylor, [email protected] Judy Holmes, [email protected] Steven M. Gutierrez; [email protected]
In addition, pursuant to D.C.COLO.LCivR. 6.1(D), the undersigned has provided a copy of this Motion to Defendant at the following e-mail address: Robert Tingey [email protected]

s/ Christopher M. Leh

3496870_1.DOC

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