Case 2:17-cv-00427-BSJ Document 34 Filed 04/26/18 Page 1 of 3 Brian S. King, #4610 BRIAN S. KING, PC 336 South 300 East, Suite 200 Salt Lake City, UT 84111 Telephone: (801) 532-1739 Facsimile: (801) 532-1936
[email protected] Attorney for Plaintiffs UNITED STATES DISTRICT COURT DISTRICT OF UTAH, CENTRAL DIVISION AMY G. and GARY G., individually and as Civil No. 2:17-cv-00427 BSJ guardians of A.G., a minor, [unopposed] MOTION TO EXTEND Plaintiffs, DEADLINE FOR PLAINTIFFS' vs. OPPOSITION MEMORANDUM UNITEDHEALTHCARE, UNITED BEHAVIORAL HEALTH, and the GEICO CORPORATION CONSOLIDATED WELFARE BENEFIT PLAN, Defendants. Plaintiffs, through their undersigned counsel, move this Court for an extension of the time frame for filing of their Opposition Memorandum (“Opposition Memo”) to the Defendants’ Motion for Summary Judgment. The Opposition Memo was due by midnight on Wednesday, April 25, 2018. It was actually filed Thursday, April 26, 2018 at 12:18 a.m., eighteen minutes late. Foreseeable, but unwished for, circumstances, together with unforeseen emotional impact from those circumstances, constitute good cause for this motion. Specifically, Plaintiffs’ counsel, in an abundance of hopefulness and positive feeling about his favorite pro basketball team, took a break from his labors on the Opposition Memo at Case 2:17-cv-00427-BSJ Document 34 Filed 04/26/18 Page 2 of 3 approximately 7:30 p.m. yesterday evening to watch Utah Jazz play the Oklahoma City Thunder in game 5 of the Round 1 NBA basketball playoffs. At approximately 9:15 p.m., in the third quarter of the game, the Jazz held a 25 point lead.