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NEI <br /> U <br /> IN THE DISTRICT COURT <br /> IN AND FOR THE CITY AND COUNTY OF DENVER, <br /> STATE OF COLORADO <br /> Civil Action No. /9-CV-1633 <br /> IUy UUU <br /> MAY 2 3 1979 <br /> THE EAGLE RIVER 1978 'TRUST, ) OFFICE OF THE <br /> CHESTER M. GOLDMAN, Trustee, ) ATTORNEY GENERAL <br /> and OLIVE McCOLLUM GOLDMAN, ) <br /> Trustee, ) <br /> Plaintiff ) <br /> PLAINTIFF' S MOTION FOR <br /> VS. ) EXTENSION OF TIME IN <br /> WHICH TO FILE MEMORANDUM <br /> THE BOARD OF MINED LAND ) BRIEF. <br /> RECLAMATION of the STATE OF ) <br /> COLORADO, and NOTTINGHAM SAND ) <br /> AND GRAVEL COMPANY, and ) <br /> individually WILLIAM E. ) <br /> NOTTINGHAM, Jr. ) <br /> Defendants. ) <br /> Plaintiffs, Eagle River 1978 Trust, Chester M. Goldman, <br /> Trustee, and Olive McCollum Goldman, Trustee, by and through <br /> their attorneys Lamm & Schader, by William P. Goldstein, <br /> respectfully request an extension of time until Monday, June 4 , <br /> 1979, within which to file a Memorandum Brief in opposition to <br /> Defendants' Motion to Dismiss or in the Alternative For Summary <br /> Judgment. <br /> As grounds for this Motion, Plaintiffs state the following : <br /> 1. Defendants filed their Motion to Dismiss or in the <br /> Alternative for Summary Judgment on April 10, 1979 , and Defendants <br /> were permitted an extension of time in which to file their <br /> Memorandum Brief in support thereof , pursuant to Local Rule 20. <br /> 2 . On May 8 , 1979, the State Defendants, The Board Of Mined <br /> Land Reclamation of the State Of Colorado, through the Attorney <br /> General ' s office, filed a Statement of Joinder in non-State <br /> Defendant Nottingham Sand and Gravel Company' s Motion. <br /> 3 . This case involves multiple parties and the Motions put <br /> in issue complex questions of law and fact which will require <br /> substantial amounts of preparation. <br />