Motion for Extension of Deadline to Complete Discovery and Order Granting Extension

• File Number: 8230.2B2
• Description: Discovery
• State: CO
• Basin: Colorado Mainstem
• Water Division: 4
• Date: 8/13/2003
• Author: Cynthia F. Covell
• Title: Motion for Extension of Deadline to Complete Discovery and Order Granting Extension
• Water Supply Pro - Doc Type: Court Documents

Upper Gunnison River Water Conservancy Disfrict
OZCW038
3. The extension is also necessary for the CWCB to take the depositions of applicant's
experts James Slattery and Gary Lacy. The deposition of Mr. Slattery as scheduled for August 18,
while that of Mr. Lacy is scheduled for August 20 and, if necessary, August 21.
4. Applicant believes that the extension is justified by the need to conduct and/or
complete the foregoing depositions. Applicant also believes that grantinl; of the extension should not
delay the trial proceedings scheduled for September 15 through 19.
EXCHANGE OF DRAFT WITNESS AND EXHIBIT LISTS
5. Pursuant to the Case Management Order, the deadline fbr exchange of draft lists of
witnesses and exhibits is August 13, 2003. Applicant believes it is not appropriate to complete
preparation of such draft lists until discovery has been completed. If the court grants the above
request to extend the discovery cut-off deadli.ne, discovery wilt be completed by August 22, 2003.
Applicant believes that such draft lists should be able to be prepared and exchanged within three days
after discovery is completed. Thus, applicant requests that the deadline for exchanging such lists be
extended from August 13, 2003 until and through August 25, 2003. If the trial management order
needs to be supplemented as a result of the granting of this request for extension, applicant will duly
supplement the trial management order.
6. Applicant believes that granting of the extension should not delay the trial proceedings
scheduled for September 15 through 19.
7. Applicant has conferted in general terms with counsel for active objector CWCB
concerni.ng this motion, although actual dates were not finalized Applicant expects to fiuther confer
at or before the teleconference scheduled with the court on August 14, 2003.
WHEREFORE, the District requests the court to grant this motion and to enter the attached
order (1) extending the discoverydeaaline until and throughAugust 22, 2003 and (2) extending the
deadline for exchange of draft witness and exhibit lists until and through August 25, 2003.
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