Unopposed MOTION for Extension of Time to File Response/Reply as to [17] MOTION to Compel by Plaintiff Melinda Sandgren. (Attachments: # (1) Proposed Order (PDF Only) Proposed Order)(Karp, Sander)
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Page 1 Case 1:04-cv-01860-WYD-OES Document 25 ~~ Filed 06/28/2005 Page 1 of3
IN THE UNITED STATES DISTRICT
COURT FOR THE DISTRICT OF COLORADO
Civil Action No. 04-cv-1860-WYD-OES
MELINDA SANDGREN,
Plaintiff,
Vv.
ASPEN VALLEY HOSPITAL DISTRICT,
Defendant.
PLAINTIFF’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY IN
SUPPORT OF PLAINTIFF’S MOTION TO COMPEL
COMES NOW the Plaintiff, Melinda Sandgren, by and through her attorneys,
Leavenworth & Karp, P.C., and respectfully moves the Court for a ten (10) day extension
of time in which to file her Reply in Support of Plaintiff's Motion to Compel. In support of
this motion, Plaintiff states as follows:
1. CERTIFICATION: The undersigned’s office contacted counsel for the
Defendant, Catherine Tallerico, regarding the substance of this Motion. Ms. Tallerico
stated that Defendant has no objection to the requested extension of time.
2. Absent an extension of time, Plaintiffs Reply in Support of her Motion to
Compel is due on June 28, 2005.Page 2 Case 1:04-cv-01860-WYD-OES Document 25 Filed 06/28/2005 Page2of3
3. Due to the heavy press of business and that Anna Itenberg, Mr. Karp’s
associate, just began her maternity leave today, the Plaintiff was unable to finalize the
reply. Plaintiff respectfully requests a ten (10) day extension of time, through and including
July 8, 2005, in which to file her reply.
4. The requested ten (10) day extension is reasonable, will not prejudice any
party in this matter, and is the first request for an extension of time.
WHEREFORE, Plaintiff respectfully requests a ten (10) day extension of time,
through and including, July 8, 2005 to file her reply in support of Plaintiffs Motion to
Compel.
Dated this 28" day of June, 2005.
LEAVENWORTH & KARP, P.C.
Attorneys for Plaintiff
By
Sander N. Karp, 1888
201 14" Street, Suite 200
PO Drawer 2020
Glenwood Spfings, CO 81602
(970) 945-2261
snk@lklawfirm.comPage 3 Case 1:04-cv-01860-WYD-OES Document 25 ~ Filed 06/28/2005 Page3of3
CERTIFICATE OF SERVICE
| hereby certify that on this 28" day of June, 2005, | electronically served the
forgoing PLAINTIFF’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE
REPLY IN SUPPORT OF PLAINTIFF’S MOTION TO COMPEL with the Clerk of the Court
through CM-ECF system which will send notification to the following e-mail address:
Catherine A. Tallerico, Esq.
Fowler Schimberg & Flanagan, P.C.
1640 Grant Street, Suite 150
Denver, CO 80203
c_tallerico@fsf-law.com F UL L OOK.
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:04-cv-01860-WYD-OES Document 25 ~~ Filed 06/28/2005 Page 1 of3
IN THE UNITED STATES DISTRICT
COURT FOR THE DISTRICT OF COLORADO
Civil Action No. 04-cv-1860-WYD-OES
MELINDA SANDGREN,
Plaintiff,
Vv.
ASPEN VALLEY HOSPITAL DISTRICT,
Defendant.
PLAINTIFF’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY IN
SUPPORT OF PLAINTIFF’S MOTION TO COMPEL
COMES NOW the Plaintiff, Melinda Sandgren, by and through her attorneys,
Leavenworth & Karp, P.C., and respectfully moves the Court for a ten (10) day extension
of time in which to file her Reply in Support of Plaintiff's Motion to Compel. In support of
this motion, Plaintiff states as follows:
1. CERTIFICATION: The undersigned’s office contacted counsel for the
Defendant, Catherine Tallerico, regarding the substance of this Motion. Ms. Tallerico
stated that Defendant has no objection to the requested extension of time.
2. Absent an extension of time, Plaintiffs Reply in Support of her Motion to
Compel is due on June 28, 2005.
PDF Page 3
Case 1:04-cv-01860-WYD-OES Document 25 Filed 06/28/2005 Page2of3
3. Due to the heavy press of business and that Anna Itenberg, Mr. Karp’s
associate, just began her maternity leave today, the Plaintiff was unable to finalize the
reply. Plaintiff respectfully requests a ten (10) day extension of time, through and including
July 8, 2005, in which to file her reply.
4. The requested ten (10) day extension is reasonable, will not prejudice any
party in this matter, and is the first request for an extension of time.
WHEREFORE, Plaintiff respectfully requests a ten (10) day extension of time,
through and including, July 8, 2005 to file her reply in support of Plaintiffs Motion to
Compel.
Dated this 28" day of June, 2005.
LEAVENWORTH & KARP, P.C.
Attorneys for Plaintiff
By
Sander N. Karp, 1888
201 14" Street, Suite 200
PO Drawer 2020
Glenwood Spfings, CO 81602
(970) 945-2261
snk@lklawfirm.com
PDF Page 4
Case 1:04-cv-01860-WYD-OES Document 25 ~ Filed 06/28/2005 Page3of3
CERTIFICATE OF SERVICE
| hereby certify that on this 28" day of June, 2005, | electronically served the
forgoing PLAINTIFF’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE
REPLY IN SUPPORT OF PLAINTIFF’S MOTION TO COMPEL with the Clerk of the Court
through CM-ECF system which will send notification to the following e-mail address:
Catherine A. Tallerico, Esq.
Fowler Schimberg & Flanagan, P.C.
1640 Grant Street, Suite 150
Denver, CO 80203
c_tallerico@fsf-law.com F UL L OOK.
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