Free Motion for Extension of Time - District Court of Colorado - Colorado

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

Document 47

Filed 08/01/2005

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. ______________________________________________________________________________ UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S FIRST COMBINED DISCOVERY REQUESTS _____________________________________________________________________________ Defendants GENERAL STEEL DOMESTIC SALES, LLC ("General Steel") GENSTONE ENTERPRISES, LLC ("Genstone") and JEFF KNIGHT ("Knight) (Collectively "Defendants"), by and through undersigned counsel hereby move for a twenty-one (21) day extension, to and including August 22, 2005, in which to respond to Plaintiff's First Set of Interrogatories and First Set of Request for Production ("Discovery Requests"). As grounds therefore Defendants state as follows: CERTIFICATE OF COMPLIANCE WITH D.COLO.L.R. 7.1A Pursuant to D.Colo.L.R. 7.1A, Defendants' counsel certifies that they have communicated with Plaintiff's counsel before filing this Motion. Plaintiff's counsel has agreed to this extension.

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

Document 47

Filed 08/01/2005

Page 2 of 3

1.

The Discovery Requests would otherwise be due on August 1, 2005. No previous

extension with respect to the Discovery Requests has been requested. 2. The Discovery Requests were served on Defendants prior to the time Plaintiff

filed the Second Amended Complaint which extensively modified the allegations. As a result, counsel needs additional time to collect information, consult with the client and coordinate with counsel in the pending litigation regarding these responses. WHEREFORE, Defendants respectfully request the Court grant an extension of time to and including August 22, 2005 to respond to Plaintiff Polyrock's outstanding Discovery Requests. Dated August 1, 2005. /s/ Kurt Lewis Kurt S. Lewis Lewis Scheid LLC 2300 Fifteenth Street, Suite 320 Denver, CO 80202 (303) 534-5040 ATTORNEYS FOR DEFENDANTS GENERAL STEEL DOMESTIC SALES, LLC GENSTONE ENTERPRISES, LLC & JEFF KNIGHT

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

Document 47

Filed 08/01/2005

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 1st day of August, 2005, I electronically filed the foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S FIRST DISCOVERY REQUESTS 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 /s/Kurt Lewis______________