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

Case 1:03-cv-00281-WDM-MJW

Document 348

Filed 08/04/2006

Page 1 of 4

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-281-WDM-MJW OLOYEA D. WALLIN, Plaintiff, v. MR. ALFARO, MR. BURK, MR. R. SATTERLY, MS. GANSEMER, MS. MILLER, Defendants. ______________________________________________________________________________ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE STIPULATION FOR DISMISSAL ______________________________________________________________________________ Defendants Charles Alfaro, Jerod Burk, Robbie Satterly, Kay Gansemer, and Pam Miller, by and through counsel, Jennifer L. Veiga, Esq. and Edmund M. Kennedy, Esq. of Hall & Evans, L.L.C., hereby submit this Motion for Extension of Time to File Stipulation for Dismissal, and as grounds therefore, state as follows: 1. Pursuant to this Court's Minute Entry for Settlement Conference dated July 19,

2006, the parties were to file a stipulation or motion to dismiss with prejudice on or before July 31, 2006. 2. Due to scheduling and other issues, including delays caused by Plaintiff's

incarceration within the Colorado Department of Corrections, the parties have been unable to

Case 1:03-cv-00281-WDM-MJW

Document 348

Filed 08/04/2006

Page 2 of 4

complete the necessary documentation in order to provide this Court with a stipulated motion to dismiss with prejudice. 3. Settlement documents have been forwarded to Plaintiff's counsel, John A.

McNamara, Esq., on July 26, 2006. Mr. McNamara has indicated that such documents will be forwarded to his client, who is currently incarcerated with the Colorado Department of Corrections next week. 4. The parties anticipate completing all the necessary documentation and submitting

a stipulated motion to dismiss on or before August 22, 2006. 5. This short extension of time will not prejudice any party or this Court. No

previous extensions have been requested. 6. Pursuant to D.C.Colo.LCivR 7.1(A), the undersigned has conferred with Mr.

McNamara concerning this Motion and has been told that Plaintiff does not oppose this Motion. 7. Pursuant to D.C.Colo.LCivR 6.1(D), a copy of this Motion has been served on

Defendants, as indicated on the certificate of mailing.

2

Case 1:03-cv-00281-WDM-MJW

Document 348

Filed 08/04/2006

Page 3 of 4

WHEREFORE, for all the foregoing reasons, Defendants respectfully requests this Court enter an Order allowing up to and including August 22, 2006, in which to submit a stipulated motion to dismiss with prejudice. Dated this 4th day of August 2006. Respectfully submitted, s/ Edmund M. Kennedy____ Jennifer L. Veiga, Esq. Edmund M. Kennedy, Esq. HALL & EVANS, L.L.C. 1125 17th Street, Suite 600 Denver, CO 80202-5800 (303) 628-3300 [email protected] [email protected] ATTORNEYS FOR DEFENDANTS

3

Case 1:03-cv-00281-WDM-MJW

Document 348

Filed 08/04/2006

Page 4 of 4

CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on this 4th day of August 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: John A. McNamara [email protected]

and I hereby certify that I have mailed or served the document or paper to the following non CM/EFC participants in the manner indicated by the non-participant's name: Defendants c/o Kelly Atwood Corrections Corporation of America 10 Burton Hills Blvd. Nashville, Tennessee 37215 s/ Marlene Wilson Secretary to Jennifer L. Veiga, Esq. Edmund M. Kennedy, Esq. Hall & Evans, L.L.C. 1125 17th Street, Suite 600 Denver, CO 80202-2052 303-628-3300 Fax: 303-293-3238 [email protected] [email protected] ATTORNEYS FOR DEFENDANTS

4