Free Motion for Extension of Time to File Response/Reply - District Court of Colorado - Colorado

Case 1:02-cv-01961-REB-MEH

Document 38

Filed 07/13/2005

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 02-1961-REB-OES (Consolidated with Civil Action Nos. 02-1962-REB-OES, 02-1963-REB-OES, 02-1979-REB-OES) THE SOCIETY OF LLOYD'S, Plaintiff, v. JOHN HENRI SILVERSMITH, Defendant.

PLAINTIFF'S MOTION FOR AN EXTENSION OF TIME TO FILE REPLY IN SUPPORT OF LLOYD'S (1) MOTION TO DISMISS COUNTERCLAIMS BASED ON IMPROPER VENUE AND (2) MOTION FOR ENTRY OF JUDGMENT [UNOPPOSED]

Plaintiff The Society Of Lloyd's ("Lloyd's"), through its undersigned counsel, respectfully requests that this Court grant it an extension of time to file its Reply in support of its (1) Motion To Dismiss Counterclaims Based On Improper Venue And (2) Motion For Entry Of Judgment. As grounds in support of this Motion, which is unopposed, Lloyd's states as follows. Pursuant to D.C.Colo.LCivR 7.1A undersigned counsel contacted opposing counsel concerning this motion and is authorized to state that opposing counsel does not oppose the extension requested. 1. Lloyd's reply in support of its Motion To Dismiss Counterclaim and its

attendant Motion For Entry Of Judgment is currently due. Lloyd's requires a twenty day extension of time, up to and including August 1, 2005 in order to file its reply.

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Case 1:02-cv-01961-REB-MEH

Document 38

Filed 07/13/2005

Page 2 of 3

2.

Lloyd's requires this extension because defendant's opposition brief

(filed as amended on June 27, 2005) is 29 pages long and has appended thereto several inches of exhibits. Due to the press of business and a long-planned vacation undersigned counsel requires more time to review the brief and finalize Lloyd's response. 3. Defendants will not be prejudiced by this short extension of time.

WHEREFORE, plaintiff The Society Of Lloyd's respectfully requests that this Court grant it up to and including August 1, 2005 within which to file its Reply. A proposed Order is attached. Dated: July 13, 2005 Denver, Colorado Respectfully submitted, HOROWITZ WAKE & FORBES s/Peter C. Forbes By Jay S. Horowitz Peter C. Forbes 370 Seventeenth Street, Suite 3950 Denver, Colorado 80202 Telephone (303) 572-5100 Telecopier (303) 572-5111 [email protected] [email protected]

Attorneys for Plaintiff The Society Of Lloyd's

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Case 1:02-cv-01961-REB-MEH

Document 38

Filed 07/13/2005

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on July 13, 2005, I electronically filed the foregoing Plaintiff's Motion For An Extension Of Time To File Reply In Support Of Lloyd's (1) Motion To Dismiss Counterclaims Based On Improper Venue And (2) Motion For Entry Of Judgment [Unopposed] with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail address: [email protected] Richard Sander, Esq. [email protected] R. Daniel Scheid, Esq. and I hereby certify that I have mailed or served the same upon the following non-CM/ECF as follows: By mail: Mr. Raymond Charlesworth Lee 5164 East Princeton Avenue Cherry Hills Village, Colorado 80110 Mr. Joseph Henri Silversmith 15 Hyde Park Circle Denver, Colorado 80209 By e-mail: Nicholas P. Demery Solicitor Lloyd's Legal Services Department One Lime Street London EC3M7HA England

HOROWITZ WAKE & FORBES s/Peter C. Forbes By Jay S. Horowitz Peter C. Forbes 370 Seventeenth Street, Suite 3950 Denver, Colorado 80202 Telephone (303) 572-5100 Telecopier (303) 572-5111 [email protected] [email protected] Attorneys for Plaintiff The Society Of Lloyd's

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