Free Motion for Extension of Time to File Response/Reply - District Court of Colorado - Colorado

Case 1:04-cv-01146-LTB-CBS

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Filed 08/23/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-1146-WMD-CBS GARY S. COHEN, Plaintiff, v. INFOLINK SCREENING SERVICES, INC., a California corporation; and PHOENIX RESEARCH, INC., an Ohio corporation, Defendants.

DEFENDANT INFOLINK SCREENING SERVICES, INC'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY TO DEFENDNAT PHOENIX RESEARCH, INC'S CROSS CLAIMS

Defendant Infolink Screening Services, Inc. ("Infolink"), by and through its attorneys, C. Todd Drake and Stephen J. Hensen of Tiemeier & Hensen, P.C., and pursuant to Fed.R.Civ.P. 6(b), moves this honorable Court for an extension of time in which to file a Reply to Defendant Phoenix Research, Inc.'s ("Phoenix") Cross Claims, through and including August 26, 2005, AND AS GROUNDS THEREFOR, state as follows: 1. Pursuant to D.C.COLO.LCivR. 7.1, the undersigned counsel has conferred

with Phoenix's counsel prior to filing this motion and Phoenix's counsel graciously agreed to the relief sought in this motion. 2. Reporting Act. This is an action for alleged negligence and violations of the Fair Credit

Case 1:04-cv-01146-LTB-CBS

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3.

Phoenix's Cross Claims were served on Infolink on August 3, 2005.

Pursuant to Fed.R.Civ.P. 12(a)(2), Infolink's Reply is due on August 23, 2005. 4. Due to the press of business, Infolink requires a brief extension of time to

allow the undersigned counsel to obtain the necessary information to adequately respond to Defendant Phoenix's Cross Claims. 5. Neither the parties nor the Court will be prejudiced by this requested brief

extension of time. WHEREFORE, Infolink respectfully requests that the Court enter an Order extending the time in which Infolink has to file a Reply to Defendant Phoenix Research, Inc.'s Cross Claims, through and including August 26, 2005, DATED this 23rd day of August, 2005. Respectfully submitted, TIEMEIER & HENSEN, P.C.

s/ C. Todd Drake_______________ C. Todd Drake Stephen J. Hensen 1515 Arapahoe Street, Suite 1300 Denver CO 80202 Telephone: 303-572-1515 Attorneys for Defendant Infolink Screening Services, Inc.

Case 1:04-cv-01146-LTB-CBS

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CERTIFICATE OF SERVICE The undersigned hereby certifies that on the 23rd day of August, 2005, a true and correct copy of the foregoing was filed and served via PACER electronic filing upon the below-noted individuals: Marc F. Bendinelli, Esq. Bendinelli Law Office, P.C. 11184 Huron Street, Suite 10 Denver, Colorado 80234 Kyle Seedorf Snell & Wilmer L.L.P. 1200 Seventeenth Street, Suite 1900 Tabor Center Denver, CO 80202

s/ Michael Jensen