Joint MOTION For Extension of Time to Extend Deadlines (Stipulated) by Plaintiff Leprino Foods Company. (Attachments: # (1) Proposed Order (PDF Only))(Heidemann, Bret)
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Case 1:03-cv-02461-MSK-MEH Document 106 Filed 05/04/2006 Page 1 of 3 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-02461-MSK-MEH LEPRINO FOODS COMPANY, Plaintiff, v.
FELDMEIER EQUIPMENT, INC.,
Defendant.
STIPULATED JOINT MOTION TO EXTEND DEADLINES
– AND –
CERTIFICATE OF COMPLIANCE WITH D.C.COLO.LCivR 6.1D Plaintiff Leprino Foods Company (“Leprino”) and Defendant Feldmeier Equipment, Inc. (“Feldmeier”), through their counsel, respectfully submit this Stipulated Joint Motion to Extend Deadlines – and – Certificate of Compliance with D.C.COLO.LCivR 6.1D. As grounds therefor, the Parties state as follows: 1.
Pursuant to the Court’s March 29, 2004 Trial Preparation Order – Jury Trial (Civil), the Parties are required to submit their Joint Exhibit List, Joint Witness List, Joint Proposed Voir Dire, Jury Instructions, Joint Verdict Forms, Joint Glossary, Joint Deposition Designations and file their Trial Briefs no later than 20 days prior to the May 26, 2006 Final Trial Preparation Conference.
2.
The Parties have scheduled a settlement conference with Magistrate Judge Hegarty on May 17, 2006, at 1:30 p.m.
If the settlement conference is successful, all of the filing deadlines would be obviated, and the Parties would save significant attorneys’fees.
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Case 1:03-cv-02461-MSK-MEH 3.
Document 106 Filed 05/04/2006 Page 2 of 3 Thus, the Parties request modification of the following deadlines: Deadline Current Requested Deadline to submit witness and exhibit lists. May 5, 2006 May 23, 2006 Deadline to submit joint proposed voir dire. May 5, 2006 May 23, 2006 Deadline to submit joint proposed jury instructions. May 5, 2006 May 23, 2006 Deadline to submit joint verdict form. May 5, 2006 May 23, 2006 Deadline to submit joint glossary.
May 5, 2006 May 23, 2006 Deadline to submit joint deposition designations. May 5, 2006 May 23, 2006 Deadline to file Trial Briefs May 5, 2006 May 23, 2006 4.
These extensions will not unduly delay these proceedings or otherwise interfere with the administration of justice. 5.
Pursuant to D.C.COLO.LCivR 6.1D, a copy of this motion is being served upon each party.
WHEREFORE, the Parties respectfully request a modification of deadlines as addressed above.
Respectfully submitted this 4th day of May 2006.
LEPRINO FOODS COMPANY
FELDMEIER EQUIPMENT, INC.
s/ Bret M. Heidemann Michael G. Bohn Bret M. Heidemann Campbell Bohn Killin Brittan & Ray, LLC 270 St. Paul Street, Suite 200 Denver, Colorado 80206
1640 Grant Street, Suite 300 Denver, Colorado 80203
(303) 298-8603 (phone) c_tallerico@fsf-law.com
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Case 1:03-cv-02461-MSK-MEH
Document 106
Filed 05/04/2006
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CERTIFICATE OF SERVICE
I hereby certify that on the 4th day of May 2006, a true and correct copy of the foregoing STIPULATED JOINT MOTION TO EXTEND DEADLINES – AND – CERTIFICATE OF COMPLIANCE WITH D.C.COLO.LCivR 6.1D was deposited in the United States mail, postage prepaid, addressed to: Jon Alby, Esq.
Leprino Foods Company 1830 W. 38th Avenue Denver, CO 80211 Feldmeier Equipment, Inc.
P.O. Box 474 Syracuse, NY 13311-0474
s/ Cori Atteberry Cori Atteberry, Legal Assistant
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Case 1:03-cv-02461-MSK-MEH
Document 106
Filed 05/04/2006
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 03-cv-02461-MSK-MEH
LEPRINO FOODS COMPANY,
Plaintiff,
v.
FELDMEIER EQUIPMENT, INC.,
Defendant.
STIPULATED JOINT MOTION TO EXTEND DEADLINES
– AND –
CERTIFICATE OF COMPLIANCE WITH D.C.COLO.LCivR 6.1D
Plaintiff Leprino Foods Company (“Leprino”) and Defendant Feldmeier
Equipment, Inc. (“Feldmeier”), through their counsel, respectfully submit this Stipulated
Joint Motion to Extend Deadlines – and – Certificate of Compliance with
D.C.COLO.LCivR 6.1D. As grounds therefor, the Parties state as follows:
1.
Pursuant to the Court’s March 29, 2004 Trial Preparation Order – Jury
Trial (Civil), the Parties are required to submit their Joint Exhibit List, Joint Witness List,
Joint Proposed Voir Dire, Jury Instructions, Joint Verdict Forms, Joint Glossary, Joint
Deposition Designations and file their Trial Briefs no later than 20 days prior to the May
26, 2006 Final Trial Preparation Conference.
2.
The Parties have scheduled a settlement conference with Magistrate
Judge Hegarty on May 17, 2006, at 1:30 p.m.
If the settlement conference is
successful, all of the filing deadlines would be obviated, and the Parties would save
significant attorneys’fees.
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Case 1:03-cv-02461-MSK-MEH
3.
Document 106
Filed 05/04/2006
Page 2 of 3
Thus, the Parties request modification of the following deadlines:
Deadline
Current
Requested
Deadline to submit witness and exhibit lists.
May 5, 2006
May 23, 2006
Deadline to submit joint proposed voir dire.
May 5, 2006
May 23, 2006
Deadline to submit joint proposed jury instructions.
May 5, 2006
May 23, 2006
Deadline to submit joint verdict form.
May 5, 2006
May 23, 2006
Deadline to submit joint glossary.
May 5, 2006
May 23, 2006
Deadline to submit joint deposition designations.
May 5, 2006
May 23, 2006
Deadline to file Trial Briefs
May 5, 2006
May 23, 2006
4.
These extensions will not unduly delay these proceedings or otherwise
interfere with the administration of justice.
5.
Pursuant to D.C.COLO.LCivR 6.1D, a copy of this motion is being served
upon each party.
WHEREFORE, the Parties respectfully request a modification of deadlines as
addressed above.
Respectfully submitted this 4th day of May 2006.
LEPRINO FOODS COMPANY
FELDMEIER EQUIPMENT, INC.
s/ Bret M. Heidemann
Michael G. Bohn
Bret M. Heidemann
Campbell Bohn Killin Brittan & Ray, LLC
270 St. Paul Street, Suite 200
Denver, Colorado 80206
(303) 322-3400 (phone)
(303) 322-5800 (fax)
mbohn@campbellbohn.com
bheidemann@campbellbohn.com
s/ Catherine Tallerico
Catherine A. Tallerico, Esq.
Fowler, Schimberg & Flanagan, P.C.
1640 Grant Street, Suite 300
Denver, Colorado 80203
(303) 298-8603 (phone)
c_tallerico@fsf-law.com
2
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Case 1:03-cv-02461-MSK-MEH
Document 106
Filed 05/04/2006
Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that on the 4th day of May 2006, a true and correct copy of the
foregoing STIPULATED JOINT MOTION TO EXTEND DEADLINES – AND –
CERTIFICATE OF COMPLIANCE WITH D.C.COLO.LCivR 6.1D was deposited in the
United States mail, postage prepaid, addressed to:
Jon Alby, Esq.
Leprino Foods Company
1830 W. 38th Avenue
Denver, CO 80211
Feldmeier Equipment, Inc.
P.O. Box 474
Syracuse, NY 13311-0474
s/ Cori Atteberry
Cori Atteberry, Legal Assistant
3
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