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

Case 1:02-cv-00289-RPM

Document 202

Filed 03/02/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 02-CV-289 RPM ROCKIE LEE ZIMMERMAN, Plaintiff, v. JOHN L. CHADBOURNE, II RUDY FANNIN, JOSH BENNER, MR. LAWRENCE, MR. DAZEY, and MR. STECKLER. Defendants.

PLAINTIFF'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANTS' RENEWED SUMMARY JUDGMENT MOTION

Plaintiff, through his counsel of record, hereby respectfully moves the Court for an extension of time to respond to Defendants; renewed summary judgment motion. As grounds, Plaintiff states: CERTIFICATION OF CONFERRAL Undersigned certifies that his legal assistant conferred with counsel for the Defendants. Counsel for the Defendants indicates that he does not object to the extension requested herein. BASES FOR MOTION 1. On February 10, 2006, Defendants filed a Renewed Motion for Summary

Judgment, with a large accompanying Brief and numerous exhibits. 2. Due to the number of issues addressed in Defendants' Renewed Motion forr

Case 1:02-cv-00289-RPM

Document 202

Filed 03/02/2006

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Summary Judgment, and the number of documents, transcripts, and other information involved, and due to the fact that undersigned counsel's family has been ill and has required undersigned to be out of the office, Plaintiff respectfully requests an additional two weeks, up to and including March 16, 2006, in which to respond to Defendants' Renewed Motion for Summary Judgment. 3. Plaintiff does not request this extension for the purpose of delay. Further, the

extension requested herein will not prejudice the Defendants, particularly given the Defendants' consent to the extension requested herein. WHEREFORE, for the foregoing reasons, Plaintiff respectfully requests an extension of up to and including March 16, 2006 in which to respond to Defendants' Renewed Motion for Summary Judgment. Pursuant to D.C. Colo. L. Civ. R. 7.1(F), a proposed Order is attached for the Court's convenience. Dated this 2nd day of March, 2006. Respectfully submitted,

s/ Troy R. Rackham_________ Troy R. Rackham McConnell Siderius Fleischner Houghtaling & Craigmile, LLC 4700 South Syracuse, Suite 200 Denver, CO 80237 Telephone: (303) 480-0400 Fax: (303) 458-9520 Email: [email protected] Attorneys for Plaintiff Rockie Lee Zimmerman

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Case 1:02-cv-00289-RPM

Document 202

Filed 03/02/2006

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CERTIFICATE OF SERVICE I hereby certify that I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system on this 2nd day of March, 2006, which will send notification of such filing to email addresses: David M. Tenner, Esq. Bond & Morris, P.C. 303 East 17th Avenue, Suite 888 Denver, Colorado 80203 [email protected] Shane White, Esq. Senior Attorney Office of the City Attorney P.O. Box 1575 30 South Nevada Avenue Colorado Springs, Colorado 80901 [email protected] And I hereby certify that I have mailed or served the document or paper to the following participants in the manner (mail, facsimile, hand-delivery, etc.) indicated by the non-participant's name: Rockie Zimmerman 1625 N. Murray Blvd., #103 Colorado Springs, CO 80915

/s/ Leah Stevens

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