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DISTRICT COURT, CITY AND COUNTY OF DENVER, COLORADO <br />Case No. 98CV5863, Courtroom 17 <br />PLAINTIFFS' MOTION FOR EXTENSION OF TIME <br />COLORADO FEDERATION OF PUBLIC EMPLOYEES, JAMES ABRAHAM, et al., <br />Plaintiffs, <br />STS <br />COLORADO DEPARTMENT OF PERSONNEL and ANDRE PETTIGREW, Executive <br />Director of the Colorado Department of Personnel, in his official <br />capacity, <br />Defendants. <br />Plaintiffs Kurt D. Albrecht, et al. (Case No. 98CV5935), by <br />and through counsel, respectfully request additional time within <br />which to file an opening brief, and as grounds therefor, state as <br />follows: <br />1. Pursuant to Order dated November 12, 1998, an opening <br />brief is due to be filed on or before December 4, 1998. <br />2. Counsel for Plaintiffs' office is in the process of <br />relocating during the period of November 23 through December 4, <br />1998, and the move has been disruptive to Counsel's preparation of <br />documents. In addition, undersigned counsel has been preparing a <br />response to the Department of Human Services' State - Operated <br />Services for Persons with Developmental Disabilities in Colorado - <br />Long -Range Plan, which is to be submitted on or before December 4, <br />1998; a reply brief in Colorado Association of Public Employees v. <br />State Board of Community Colleges and Occupational Education, <br />Colorado Supreme Court Case No. 98SC641, which is due to be filed <br />on December 9, 1998; and a notice of appeal in Petition of CAPE and <br />AFSCME, State Personnel Board Case No. 97D001, which is due to be <br />filed on December 11, 1998. <br />3. Therefore, an additional week, or through and including <br />December 11, 1998, will be needed within which to draft and <br />research an opening brief. <br />