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

Case 1:02-cv-00671-ZLW-BNB

Document 212

Filed 09/18/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 02-cv-00671-ZLW-BNB DIANE C. McINNIS Plaintiff, v. FAIRFIELD COMMUNITIES, INC., d/b/a, FAIRFIELD RESORTS, INC., a Delaware corporation, Defendant.

UNOPPOSED MOTION FOR EXTENSION OF TIME RE: COURT'S ORDER DATED SEPTEMBER 14, 2006

Plaintiff submits the following unopposed Motion: 1. Plaintiff's counsel conferred with Defendant's counsel concerning this Motion.

Defendant is not opposed to this Motion. 2. Plaintiff requests a 30-day extension of time to file her bill of costs and reply brief

addressing the issue of attorneys' fees, and to confer with opposing counsel concerning Plaintiff's front pay and file a joint status report. Plaintiff needs additional time to collect costs and receipts from two years ago. In addition, pursuant to the Tenth Circuit's ruling in this case, Plaintiff is having an expert review her attorneys' fees and needs additional time for the expert to complete his report. Finally, Plaintiff needs additional time to research Plaintiff's front pay. 3. As a result, Plaintiff is requesting an extension of time to file her bill of costs up to

and including October 23, 2006. 1

Case 1:02-cv-00671-ZLW-BNB

Document 212

Filed 09/18/2006

Page 2 of 2

4.

Plaintiff is also requesting an extension of time to file her reply brief addressing the

issue of attorneys' fees up to and including November 6, 2006. 5. Finally, Plaintiff requests an extension of time to confer with Defendant's counsel

concerning Plaintiff's front pay award up to and including October 23, 2006. To that end, Plaintiff also requests an extension for counsel to file a joint status report concerning front pay up to and including November 6, 2006. DATED this 18th day of September, 2006. ELWYN F. SCHAEFER & ASSOCIATES, P.C. _/s Andrea J. Kershner______________________ Elwyn F. Schaefer Andrea J. Kershner 600 17th Street, Suite 2005 South Denver, Colorado 80202 (303) 825-1961 Attorneys for Plaintiff Certificate of Service I hereby certify that on this 18th day of September, 2006 a true and correct copy of the foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME RE: COURT'S ORDER DATED SEPTEMBER 14, 2006 was filed electronically with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: K. Preston Oade, Jr. [email protected] _/s Lori Fraser, Legal Assistant

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