Free Motion to Amend/Correct/Modify - District Court of Colorado - Colorado

Case 1:04-cv-00617-LTB-BNB

Document 63

Filed 08/22/2005

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Case No. 04-cv-0617-LTB-BNB POLYROCK TECHNOLOGIES, LLC, a Colorado limited liability company, Plaintiff, vs. GENERAL STEEL DOMESTIC SALES, LLC, a Colorado limited liability company, d/b/a General Steel Corporation; GENSTONE ENTERPRISES, LLC, a Colorado limited liability company, d/b/a GenStone; JEFF KNIGHT; KEVIN KISSIRE; and CHUCK DEMAREST, Defendants. ______________________________________________________________________________ STIPULATED MOTION TO AMEND SCHEDULING ORDER REGARDING DEFENDANTS' DISCLOSURES AND TO EXTEND TIME TO RESPOND TO PLAINTIFF'S FIRST COMBINED DISCOVERY REQUESTS PENDING ENTRY OF PROTECTIVE ORDER _____________________________________________________________________________ The Parties, by and through their undersigned counsel, hereby stipulate to amend the Scheduling Order with respect to the Defendants' Disclosures and Defendants' Response to Plaintiff's First Combined Discovery Requests. As grounds therefore the parties state as follows: CERTIFICATE OF COMPLIANCE WITH D.COLO.L.R. 7.1A The Parties have agreed to this Stipulated Motion to Amend Scheduling Order Regarding Defendants' Disclosures and To Extend Time to Respond to Plaintiff's First Combined Discovery Requests Pending Entry of Protective Order. 1. The Parties have agreed to finalize a Protective Order in the next few days and to

extend the time for Defendants to make disclosures and respond to outstanding Discovery Requests to a date five days following the Court's entry of the Protective Order.

Case 1:04-cv-00617-LTB-BNB

Document 63

Filed 08/22/2005

Page 2 of 3

2.

Defendants have received a draft Protective Order from the Plaintiff and the

parties anticipate filing a Joint Motion for Protective Order no later than Wednesday August 24, 2005. 3. The Scheduling Order set the date for Defendants to file disclosures in this matter

as August 22, 2005. Defendants Genstone, General Steel and Knight were to respond to Plaintiff Polyrock's outstanding Discovery Requests at the same time. Defendant Demarest's responses to Plaintiff Polyrock's outstanding Discovery Requests are due August 24, 2005. WHEREFORE, the Parties request the Court to enter an Order extending the time for all Defendants to file Disclosures and to respond to Plaintiff's outstanding Discovery Requests to a date five days following the Court's entry of the Protective Order. Dated: August 22, 2005. s/ John A. DeSisto John A. DeSisto, FEATHERSTONE DESISTO LLP 600 17th Street, #2400 Denver, CO 80202 Telephone: 303 626-7100 Facsimile: 303 626-7101 e-mail: [email protected] Attorney for Plaintiff PolyRock Technologies, LLC s/Kurt Lewis Kurt S. Lewis LEWIS SCHEID LLC 2300 15th Street #320 Denver, CO 80202 Telephone: 303 534-5040 Facsimile: 303 534-5039 fax e-mail: [email protected] Attorneys for Defendants General Steel Domestic Sales, LLC; Genstone Enterprises, LLC and Jeff Knight; s/ Susan M. Hargleroad Susan M. Hargleroad PENDLETON, FRIEDBERG, WILSON & HENNESSEY, P.C. 1875 Lawrence Street, 10th Floor Denver, CO 80202 Telephone: 303 839-1204 Facsimile: 303 831-0786 fax e-mail: [email protected]

Case 1:04-cv-00617-LTB-BNB

Document 63

Filed 08/22/2005

Page 3 of 3

Attorney for Defendant Charles Demarest.
CERTIFICATE OF SERVICE I hereby certify that on this 22nd day of August, 2005, I electronically filed the foregoing

STIPULATED MOTION TO AMEND SCHEDULING ORDER REGARDING DEFENDANTS' DISCLOSURES AND TO EXTEND TIME TO RESPOND TO PLAINTIFF'S FIRST COMBINED DISCOVERY REQUESTS PENDING ENTRY OF PROTECTIVE ORDER with the Clerk of court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: John A. DeSisto E-mail: [email protected] Susan M. Hargleroad E-mail: [email protected] AND SERVED VIA US MAIL, POSTAGE PREPAID TO: Richard Taub General Steel Corporation 1075 South Yukon Street, Suite 250 Lakewood, CO 80224 Jeff Knight General Steel Corporation 1075 South Yukon Street, Suite 250 Lakewood, CO 80224 Genstone Enterprises 1075 South Yukon Street, Suite 250 Lakewood, CO 80224 Charles Demarest 740 S. Pierce Avenue Louisville, CO 80027 PolyRock Technologies, LLC 4949 South Syracuse, Suite 340 Denver, CO 80237 s/ Kurt Lewis