Unopposed MOTION for Extension of Time to File Reply Regarding [114]Motion for Summary Judgment by Defendants Wembley USA Inc., Wembley Inc., Robert Ty Howard. (Mix, Kristen) (Modified on 2/13/2006 to link entry to motion) (pap, ).
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Case 1:03-cv-01793-EWN-BNB Document 117 Filed 01/05/2006 Page 1 of 3 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-01793-EWN-BNB PATRICIA A. EMERSON, Plaintiff, v.
WEMBLEY USA, INC.; WEMBLEY INC.;
ROBERT TY HOWARD in his personal capacity; and JEFFREY GOERGEN in his personal capacity, Defendants.
______________________________________________________________________________ DEFENDANTS’ UNOPPOSED MOTION FOR ONE DAY EXTENSION OF TIME TO FILE REPLY REGARDING MOTION FOR SUMMARY JUDGMENT ______________________________________________________________________________ Defendants Wembley, Inc., Wembley USA, Inc. and Robert Ty Howard, through their attorneys Snell & Wilmer L.L.P., hereby respectfully request that the Court grant a one-businessday extension of time for them to file their Reply regarding their Motion for Summary Judgment in this matter. As grounds therefor, Defendants state as follows: 1.
Defendants filed their Second Renewed Motion for Summary Judgment on December 9, 2005. Plaintiff filed her response on December 22, 2005. Pursuant to D.C.COLO.L.R. 7.1(c), Defendants’ Reply is currently due on January 6, 2006. 2.
Due to the press of other business, Defendants’ counsel requires a one-businessday extension of time, until January 9, 2006, to complete and file Defendants’ Reply with the Court.
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Pursuant to D.C.COLO.L.R. 7.1(A), undersigned counsel hereby certifies that she
conferred with opposing counsel regarding the relief requested in this motion and opposing counsel indicated that she has no objection.
WHEREFORE, Defendants respectfully request that the Court enter an Order granting an extension of time for Defendants to file their Reply regarding their Motion for Summary Judgment until January 9, 2006, and that the Court grant such other and further relief as the Court deems just and proper in the premises.
Dated this 5th day of January, 2006.
Respectfully submitted,
s/Kristen L. Mix Kristen L. Mix SNELL & WILMER L.L.P.
1200 Seventeenth Street, Suite 1900 Denver, Colorado 80202 Telephone: (303) 634-2000 Facsimile: (303) 634-2020 ATTORNEYS FOR DEFENDANTS WEMBLEY USA, INC., WEMBLEY, INC., AND ROBERT TY HOWARD
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CERTIFICATE OF SERVICE
The undersigned does hereby certify that on this 5th day of January, 2006, a true and correct copy of the foregoing DEFENDANTS’ UNOPPOSED MOTION FOR ONE DAY EXTENSION OF TIME TO FILE REPLY REGARDING MOTION FOR SUMMARY JUDGMENT was served via ECF electronic filing on the following: Attorneys for Plaintiff Bradley N. Shefrin, Esq.
Melissa Clack, Esq.
ZUPKUS & ANGELL, PC
555 E. 8th Ave.
Denver, CO 80203 Telephone: 303-894-8948 Facsimile: 303-894-0104 Attorneys for Defendant Jeffrey Goergen David H. Stacy, Esq.
DUCKER MONTGOMERY & ARONSTEIN, P.C.
1560 Broadway, Suite 1400 Denver, CO 80202-5151 Telephone: (303) 228-2529 Facsimile: (303) 861-4017
s/Sarah McPherson Sarah McPherson
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Case 1:03-cv-01793-EWN-BNB
Document 117
Filed 01/05/2006
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 03-cv-01793-EWN-BNB
PATRICIA A. EMERSON,
Plaintiff,
v.
WEMBLEY USA, INC.; WEMBLEY INC.;
ROBERT TY HOWARD in his personal capacity; and
JEFFREY GOERGEN in his personal capacity,
Defendants.
______________________________________________________________________________
DEFENDANTS’ UNOPPOSED MOTION FOR ONE DAY EXTENSION
OF TIME TO FILE REPLY REGARDING MOTION FOR SUMMARY JUDGMENT
______________________________________________________________________________
Defendants Wembley, Inc., Wembley USA, Inc. and Robert Ty Howard, through their
attorneys Snell & Wilmer L.L.P., hereby respectfully request that the Court grant a one-businessday extension of time for them to file their Reply regarding their Motion for Summary Judgment
in this matter. As grounds therefor, Defendants state as follows:
1.
Defendants filed their Second Renewed Motion for Summary Judgment on
December 9, 2005. Plaintiff filed her response on December 22, 2005. Pursuant to
D.C.COLO.L.R. 7.1(c), Defendants’ Reply is currently due on January 6, 2006.
2.
Due to the press of other business, Defendants’ counsel requires a one-business-
day extension of time, until January 9, 2006, to complete and file Defendants’ Reply with the
Court.
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Pursuant to D.C.COLO.L.R. 7.1(A), undersigned counsel hereby certifies that she
conferred with opposing counsel regarding the relief requested in this motion and opposing
counsel indicated that she has no objection.
WHEREFORE, Defendants respectfully request that the Court enter an Order granting an
extension of time for Defendants to file their Reply regarding their Motion for Summary
Judgment until January 9, 2006, and that the Court grant such other and further relief as the
Court deems just and proper in the premises.
Dated this 5th day of January, 2006.
Respectfully submitted,
s/Kristen L. Mix
Kristen L. Mix
SNELL & WILMER L.L.P.
1200 Seventeenth Street, Suite 1900
Denver, Colorado 80202
Telephone: (303) 634-2000
Facsimile: (303) 634-2020
ATTORNEYS FOR DEFENDANTS
WEMBLEY USA, INC., WEMBLEY, INC.,
AND ROBERT TY HOWARD
2
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CERTIFICATE OF SERVICE
The undersigned does hereby certify that on this 5th day of January, 2006, a true and correct copy
of the foregoing DEFENDANTS’ UNOPPOSED MOTION FOR ONE DAY EXTENSION
OF TIME TO FILE REPLY REGARDING MOTION FOR SUMMARY JUDGMENT was
served via ECF electronic filing on the following:
Attorneys for Plaintiff
Bradley N. Shefrin, Esq.
Melissa Clack, Esq.
ZUPKUS & ANGELL, PC
555 E. 8th Ave.
Denver, CO 80203
Telephone: 303-894-8948
Facsimile: 303-894-0104
Attorneys for Defendant Jeffrey Goergen
David H. Stacy, Esq.
DUCKER MONTGOMERY & ARONSTEIN, P.C.
1560 Broadway, Suite 1400
Denver, CO 80202-5151
Telephone: (303) 228-2529
Facsimile: (303) 861-4017
s/Sarah McPherson
Sarah McPherson
3
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