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Case 1:03-cv-02461-MSK-MEH Document53 _ Filed 06/20/2005 Page 1 of3 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-2461-MK-OES LEPRINO FOODS COMPANY, Plaintiff, V.
FELDMEITER EQUIPMENT, INC.,
& Defendant.
UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMBINED FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO DEFENDANT
Defendant Feldmeier Equipment, Inc., by and through counsel Fowler, Schimberg & Flanagan, P.C., hereby moves for an extension of the time to respond to Plaintiff’s Combined First Set Of Interrogatories And Requests For Production Of Documents To Defendant. Defendant respectfully requests an extension up to, and including June 22, 2005, and states as follows:
I. D.C. COLO. L.CivR 7.1 CERTIFICATION Defendant's counsel conferred with Plaintiff's counsel regarding this motion and the relief requested herein. Plaintiff's counsel is not opposed to this motion.
I. ARGUMENT
1. Defendant's response to Plaintiff's Combined First Set Of Interrogatories And Requests For Production Of Documents are due on June 20, 2005.
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Case 1:03-cv-02461-MSK-MEH Document53 _ Filed 06/20/2005 Page 2of3
2. Defendant is unable to file and serve responses to Plaintiff's Combined First Set Of Interrogatories And Requests For Production Of Documents by June 20, 2005, due to the fact that the undersigned has been out of town attending to depositions in other matters.
3. Defendant respectfully requests up to, and including June 22, 2005 to respond to Plaintiffs Combined First Set Of Interrogatories And Requests For Production Of Documents.
4. Granting Defendant an extension of time will allow the Defendant time to appropriately and comprehensively respond to Plaintiff's discovery requests.
5. This Extension of the Deadline of Defendant’s Response to Plaintiff's Combined Demands is not for the purpose of delay.
6. The extension of time will not prejudice any party. Trial is not scheduled until June 26, 2006.
WHEREFORE, Defendant respectfully requests the Court grant this Motion and allow Defendant up to, and including June 22, 2005 to respond to Plaintiff's Combined First Set Of Interrogatories And Requests For Production Of Documents To Defendant. Respectfully submitted this 20th day of June, 2005.
FOWLER, SCHIMBERG & FLANAGAN, P.C.
“wn Catherine A. Tallerico 1640 Grant Street Denver, Colorado 80203 Telephone: 303.298.8603 ATTORNEYS FOR DEFENDANT
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Case 1:03-cv-02461-MSK-MEH Document53 _ Filed 06/20/2005 Page 3of3
CERTIFICATE OF SERVICE
| hereby certify that on this 20th day June, 2005, I caused a true and correct copy of the foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMBINED FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO DEFENDANT to be served by the Regular U.S. Mail to:
Michael G. Bohn, Esq.
Campbell Bohn Killin Brittan & Ray, LLC 270 St. Paul Street, Ste. 200
Denver, CO 80206
Mr. Jake Feldmeier Feldmeier Equipment, Inc.
6800 Townline Road Syracuse, NY 13211
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