CRP's (1st) Motion For Extension of Time

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DATE FILED: March 27, 2015 4:58 PM

FILING ID: 98F55F9F8CADC


CASE NUMBER: 2014CA1945

COLORADO COURT OF APPEALS


2 East 14th Avenue
Denver, CO 80203
______________________________________________
Plaintiff/Appellee:
PARTY

COLORADO

REPUBLICAN
COURT USE ONLY

v.
Defendant/Appellee: SCOTT GESSLER, in his official
capacity as Colorado Secretary of State

Case Number: 2014CA001945

and
Intervenor Defendant/Appellant: Colorado Ethics
Watch
______________________________________________
Attorneys for Plaintiff/Appellee Colorado Republican
Party:
Richard A. Westfall, No. 15295
Allan L. Hale, No. 14885
Peter J. Krumholz, No. 27741
Hale Westfall, LLP
1600 Stout St., Suite 500
Denver, CO 80202
Phone 720-904-6010
Fax 720-904-6020
rwestfall@halewestfall.com
UNOPPOSED MOTION FOR EXTENSION OF TIME
Appellee Colorado Republican Party (CRP), by its undersigned counsel, hereby moves
for a 30-day extension of time, to and including May 11, 2015, in which to file its Answer Brief
in the above-captioned appeal. In support, CRP states as follows:
1.

Appellant Colorado Ethics Watch filed its Opening Brief on March 6, 2015.

Accordingly, CRPs Answer Brief is due on or before April 10, 2015.

2.

Undersigned counsel, who has primary responsibility for drafting the Answer

Brief on CRPs behalf, will be out of town on vacation during the week of March 30, 2015. In
addition, recent changes in CRP leadership require counsel for the CRP to meet with the new
leadership concerning, among other things, this appeal. Counsel has not yet had an opportunity
to meet with CRPs new leadership.
3.

Accordingly, CRP respectfully moves for a 30-day extension of time, to and

including May 11, 2015, in which to file its Answer Brief. This extension of time will give
counsel, in the exercise of diligence, sufficient time to meet with the new party leadership, and
prepare and file the Answer Brief.
4.

Undersigned counsel has conferred with counsel for Colorado Ethics Watch

concerning this requested extension. Colorado Ethics Watch does not oppose this extension of
time. CRP has not previously requested any extensions of time in this appeal, and the granting of
this request will not unduly delay the progress of this action or prejudice any party.
Respectfully submitted this 27th day of March, 2015.
HALE WESTFALL, LLP
By :s/Peter J. Krumholz
Peter J. Krumholz, Reg. No. 27741
Attorneys for Colorado Republican Party

CERTIFICATE OF SERVICE
I hereby certify that on this 27th day of March, 2015, a true and correct copy of the
foregoing pleading was served via ICCES on the following:
Matthew D. Grove
Sueanna Johnson
Colorado Attorney Generals Office
State Services Section
1300 Broadway, 6th Floor
Denver, CO 80203
Luis Toro
Margaret Perl
Colorado Ethics Watch
1630 Welton St., Suite 415
Denver, CO 80202
s/Bethany Lillis
Bethany Lillis

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