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2. Because the Court had already entered an order granting the Motion, Plaintiffs were <br />unable to merely move for an extension of time, but had to also move the Court to set aside its order. <br />Plaintiffs' counsel stated in their Motion to Set Aside Order that it had conferred with <br />counsel for DRMS and that said counsel did not oppose the motion. The purpose of this filing is to <br />clarify that Plaintiff conferred with opposing counsel who agreed upon an enlargement of time, but <br />that conversation took place before the Court entered its Order granting the motion. Plaintiffs' <br />counsel, acting in good faith, presumed that the prior conference with counsel for DRMS was <br />sufficient and that counsel did not oppose its motion based on its agreement to an extension of the <br />time for Plaintiffs' response and the fact that the Court's order was entered before the Plaintiffs' <br />response was due. However, undersigned counsel now recognizes that it was an error to so presume. <br />4. Undersigned counsel has now conferred with counsel for DRMS, who opposes the <br />relief requested in Plaintiff's Motion to Set Aside Order. <br />Submitted this 27`h day of April, 2011. <br />DUFFORD, WALDECK, MILBURN & KROHN, L.L.P. <br />[Original signature on file at the offices of Dufford, Waldeck, <br />Milburn & Krohn, LLP] <br />By: /s/ Carin Ramirez <br />Carin Ramirez, #42744 <br />Attorneys for Plaintiffs <br />