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

Case 1:03-cv-00097-WDM-MJW

Document 245

Filed 06/27/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Case No.: 03-WM-97 (MJW)

PRAIRIELAND PROCESSORS, INC., a Colorado corporation, Plaintiff and Counterclaim Defendant, v. RIDGEFIELD FARMS, LLC, a Connecticut limited liability corporation, Defendant and Counterclaim Plaintiff, and WEST-CONN MEAT CO., INC., a Connecticut corporation, and RICHARD GREENFIELD, Counterclaim Defendants,

UNOPPOSED MOTION TO EXTEND TIME TO FILE BILL OF COSTS

Pursuant to D.C.Colo.LCivR 7.1A and Fed.R.Civ.P. 6(b), Plaintiff and Counterclaim Defendant Prairieland Processors, Inc. (Prairieland), by its undersigned counsel, submits unopposed motion to extend time to file Bill of Costs, and as grounds for this motion, states as follows: CERTIFICATE OF COMPLIANCE WITH D.C.COLO.LCivR 7.1.A The undersigned counsel states that he conferred with Frank Visciano, Esq., counsel for Defendants Ridgefield Farms, LLC ("Ridgefield"), West-Conn Meat Company, Inc. and Richard Greenfield, concerning this Motion on June 26, 2006 and was authorized by Mr. Visciano to state that this Motion is unopposed.

Case 1:03-cv-00097-WDM-MJW

Document 245

Filed 06/27/2006

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1.

Judgment entered in favor of Prairieland and against Defendant Ridgefield Farms,

LLC on June 13, 2006. The Judgment awarded costs to Prairieland upon filing a Bill of Costs within ten days from entry of judgment. As computed under Fed.R.Civ.P. 6(a), the last day for filing a Bill of Costs is June 27, 2006. 2. Prairieland requires additional time to assemble its costs and to compile

supporting documents and requests an extension of the time to file a Bill of Costs to July 10, 2006, which is an extension of eight days as computed under Fed.R.Civ.P. 6(a). 3. In accordance with D.C.Colo.LCivR 7.1, the undersigned counsel has served this

motion upon Prairieland in the manner indicated in the Certificate of Service attached hereto. 4. As stated in the above Certificate of Compliance with D.C.COLO.LCivR 7.1.A,

counsel for Defendants has authorized counsel to state that this Motion is unopposed. Wherefore, Plaintiff Prairieland Processors, Inc. requests that the Court enter an Order extending the time within which Prairieland may file a Bill of Costs by to and including July 10, 2006. Respectfully submitted this 27th day of June 2006.

s/Marcus L. Squarrell Marcus L. Squarrell David S. Stacy DUCKER, MONTGOMERY, ARONSTEIN & BESS, P.C. 1560 Broadway, Suite 1400 Denver, Colorado 80202 Telephone: (303) 861-2828 Facsimile: (303) 861-2017 Email: [email protected] [email protected] ATTORNEYS FOR PLAINTIFF AND DEFENDANT ON COUNTERCLAIMS

By:

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Case 1:03-cv-00097-WDM-MJW

Document 245

Filed 06/27/2006

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CERTIFICATE OF SERVICE The undersigned hereby certifies that on the 27th day of June 2006 a true and correct copy of the foregoing MOTION TO EXTEND TIME FOR FILING BILL OF COSTS was filed electronically with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following email addresses: [email protected] [email protected] Frank W. Visciano, Esq. Luis A. Toro, Esq. SENN · VISCIANO · KIRSCHENBAUM · MERRICK P.C. 1801 California Street, Suite 4300 Denver, Colorado 80202 Facsimile: 303-296-9101 Via United States mail, postage prepaid, addressed to the following: Prairieland Processors, Inc. c/o Richard Jochum Beef Products, Inc. 891 Two Rivers Drive Dakota Dunes, South Dakota 57049

By:

s/Marcus L. Squarrell Marcus L. Squarrell David S. Stacy DUCKER, MONTGOMERY, ARONSTEIN & BESS, P.C. 1560 Broadway, Suite 1400 Denver, Colorado 80202 Telephone: (303) 861-2828 Facsimile: (303) 861-2017 Email: [email protected] [email protected]

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