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COLORADO COURT OF APPEALS 2 East 14 th Avenue Denver, CO 80203 ______________________________________________ Plaintiff/Appellee: COLORADO REPUBLICAN PARTY v. Defendant/Appellee: SCOTT GESSLER, in his official capacity as Colorado Secretary of State 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 [email protected] COURT USE ONLYCase Number: 2014CA001945 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, CRP’s Answer Brief is due on or before April 10, 2015. DATE FILED: March 27, 2015 4:58 PM FILING ID: 98F55F9F8CADC CASE NUMBER: 2014CA1945

CRP's [1st] Motion for Extension of Time

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Colorado Republican Party's first motion for extension of time to file its answer brief in Colorado Republican Party v. Colorado Ethics Watch, et al., Colorado Court of Appeals

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Page 1: CRP's [1st] Motion for Extension of Time

COLORADO COURT OF APPEALS 2 East 14th Avenue Denver, CO 80203 ______________________________________________

Plaintiff/Appellee: COLORADO REPUBLICAN PARTY v. Defendant/Appellee: SCOTT GESSLER, in his official capacity as Colorado Secretary of State 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 [email protected]

▲COURT USE ONLY▲ Case Number: 2014CA001945

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, CRP’s Answer Brief is due on or before April 10, 2015.

DATE FILED: March 27, 2015 4:58 PM FILING ID: 98F55F9F8CADC CASE NUMBER: 2014CA1945

Page 2: CRP's [1st] Motion for Extension of Time

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2. Undersigned counsel, who has primary responsibility for drafting the Answer

Brief on CRP’s 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 CRP’s 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

Page 3: CRP's [1st] Motion for Extension of Time

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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 General’s 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