Free Motion to Continue - District Court of Colorado - Colorado

Case 1:02-cv-01736-EWN-MJW

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Filed 08/03/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 02-cv-1736-EWN-MJW ROBERT STONE, Plaintiff, v. DEPARTMENT OF AVIATION, DENVER INTERNATIONAL AIRPORT and THE CITY AND COUNTY OF DENVER, a Municipal Corporation, Defendants. ______________________________________________________________________________ UNOPPOSED MOTION TO CONTINUE STATUS CONFERENCE ______________________________________________________________________________ Plaintiff, through counsel, pursuant to D.C.COLO.L.Civ.R. 6.1 and Fed.R.Civ.P. 6, moves for an order granting him a continuance of the Status Conference currently set for August 11, 2006 at 2:30 p.m. Certification pursuant to D.C.COLO.L.Civ.R. 7.1: Undersigned counsel hereby certifies that she has conferred with Jack Wesoky, counsel for the Defendants, who does not oppose the relief requested herein. As grounds for this Motion, Plaintiff states: 1. Lead trial counsel for the Plaintiff, David Lichtenstein, is out of town during the first two

Case 1:02-cv-01736-EWN-MJW

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weeks of August, including August 11, 2006, and will return on August 14, 2006. 2. All counsel are available on the following dates for the status conference, and have agreed that any of these dates are acceptable: Monday August 14, 2006 after ten o'clock am; Tuesday August 15, 2006; Wednesday August 16, 2006; Thursday August 17, 2006 between eight and nine o'clock am and after four pm; Friday August 18, 2006 between eight and nine o'clock am; Monday August 21, 2006 before two o'clock pm; Tuesday August 22, 2006 between eight and nine-thirty am and after twelve-thirty pm; Wednesday August 23, 2006; Thursday August 24, 2006. 3. 4. No party will be prejudiced by the granting of the relief requested herein. A proposed form of Order is filed herewith. WHEREFORE, Plaintiff Robert Stone respectfully requests a continuance of the Status Conference currently set for August 11, 2006 at 2:30 p.m. DATED: August 3, 2006. s/Jennifer C. Bergsieker Jennifer C. Bergsieker David Lichtenstein, Attorney at Law 1556 Williams St., Suite 100 Denver, CO 80218-1635 Phone: (303) 831-4750 Facsimile: (303) 863-0835 E-mail: [email protected] Attorney for Plaintiff Robert Stone CERTIFICATE OF SERVICE I certify that on August 3, 2006, I electronically filed the foregoing with the Clerk of court using

Case 1:02-cv-01736-EWN-MJW

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Filed 08/03/2006

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the CM/ECF system which will send notification of such filing to the following e-mail addresses: Jack M. Wesoky, Esq. Robert Douglas Nespor, Esq. Mindi Lynn Wright, Esq. [email protected] [email protected] [email protected]

I further certify that on August 3, 2006, I mailed or served the document or paper to the following participants in the manner (mail, hand-delivery, etc.) indicated by the non-participant's name:

Robert Stone 12658 E. Arkansas Drive Aurora, CO 80017 s/ Jennifer C. Bergsieker Jennifer C. Bergsieker David Lichtenstein, Attorney at Law 1556 Williams St., Suite 100 Denver, CO 80218-1635 Phone: (303) 831-4750 Facsimile: (303) 863-0835 E-mail: [email protected] Attorney for Plaintiff Robert Stone