Free Motion to Vacate - District Court of Colorado - Colorado

Case 1:02-cv-02216-WYD-KLM

Document 495

Filed 02/15/2008

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 02-cv-02216-WYD-KLM

ROYAL INDEMNITY COMPANY, a Delaware corporation, Plaintiff, v. AMERICAN FAMILY MUTUAL INSURANCE COMPANY, a Wisconsin corporation; AMERICAN STATES INSURANCE COMPANY, an Indiana corporation, Defendants. ______________________________________________________________________________ DEFENDANT AMERICAN FAMILY'S MOTION TO VACATE AND RESET THE HEARING DATE OF MARCH 14, 2008 ______________________________________________________________________________ Defendant American Family Mutual Insurance Company, by and through its counsel, Lambdin & Chaney, LLP, hereby moves this Court to vacate and reset the hearing date of March 14, 2008, on the pending motions for summary judgment and in support states as follows: The undersigned counsel for Defendant American Family Mutual Insurance Company will be in trial in the matter of: Law v. American National Property and Casualty Company, Case No. 04cv4399, El Paso County District Court, Division 13. The parties had their trial readiness conference this week and the court informed the parties that the Law case is the only case on the docket and it will go to trial. The trial is scheduled for 10 days from March 10th through March 21st, 2008. WHEREFORE, American Family respectfully requests that this Court vacate and reset the current hearing date of March 14, 2008.

Case 1:02-cv-02216-WYD-KLM

Document 495

Filed 02/15/2008

Page 2 of 2

Respectfully submitted, LAMBDIN & CHANEY, LLP

By:

/s/ L. Kathleen Chaney L. Kathleen Chaney Attorneys for Defendant American Family LAMBDIN & CHANEY, LLP 4949 S. Syracuse Street, Suite 600 Denver, Colorado 80237 Telephone: (303) 799-8889 FAX: (303) 799-3700 E-mail: [email protected]

CERTIFICATE OF SERVICE I hereby certify that on this 15th day of February, 2008, a true and correct copy of the foregoing DEFENDANT AMERICAN FAMILY'S MOTION TO VACATE AND RESET THE HEARING DATE OF MARCH 14, 2008 was sent to the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following email addresses: Laurence M. McHeffey, Esq. Jonathan A. Decker, Esq. McElroy, Deutsch & Mulvaney, LLP 1700 Broadway, Suite 1900 Denver, Colorado 80290 Attorneys for Plaintiffs Joseph C. Jaudon, Esq. David H. Yun, Esq. Jaudon & Avery, LLP 1660 Wynkoop St., Suite 1010 Denver, CO 80202 Attorneys for American States Insurance Company .

By:

s/ L. Kathleen Chaney L. Kathleen Chaney, Esq. Attorneys for American Family LAMBDIN & CHANEY, LLP

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