Free Motion for Extension of Time to File Answer - District Court of Colorado - Colorado

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

Document 46

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 SECOND AMENDED COMPLAINT _____________________________________________________________________________ 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 ten (10) day extension, to and including August 11, 2005, in which to respond or otherwise answer to Plaintiff's Second Amended Complaint ("Complaint"). 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 46

Filed 08/01/2005

Page 2 of 3

1.

The Court approved the Plaintiff's Unopposed Motion to file their Second

Amended Complaint on July 20, 2005. Defendants' response to the Second Amended Complaint is due on August 1, 2005. 2. Plaintiff's Second Amended Complaint extensively modified the allegations of

the Complaint. As a result, counsel needs additional time to collect information, consult with the client and coordinate with counsel in the pending litigation regarding a response to Plaintiff's Second Amended Complaint. WHEREFORE, Defendants respectfully request the Court grant an extension of time to and including August 11, 2005 to respond to Plaintiff Polyrock's Second Amended Complaint. 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 46

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 SECOND AMENDED COMPLAINT 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