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

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

Document 105

Filed 11/15/2005

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 AMEND ANSWER 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 seven (7) day extension, to and including November 23, 2005, in which to amend the pleadings and join additional parties. As grounds therefore, Defendants state as follows: CERTIFICATE OF COMPLIANCE WITH D.C.Colo.LCivR. 7.1A Pursuant to D.C.Colo.LCivR. 7.1A, Defendants' counsel certifies that they have communicated with Plaintiff's counsel and Defendant Demarest's counsel before filing this Motion. The respective counsels do not oppose this extension or the filing of this Motion.

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

Document 105

Filed 11/15/2005

Page 2 of 3

1.

Prior to this Motion the parties have filed one Joint Motion to Extend Deadline to

Amend Pleadings, filed on October 14, 2005. On October 17, 2005, the Court approved this Joint Motion to Extend Deadline to Amend Pleadings, to and including November 16, 2005. 2. Defendants have been diligently investigating and analyzing the issues related to

this matter and therefore request a one-week extension of time to determine whether they will be moving to amend pleadings in this case, or join additional parties. No party will be prejudiced by this extension of time, and the other parties do not oppose this request. Defendants request this extension to the deadline to amend the pleadings pursuant to Fed.R.Civ.P. 15 and D.C.COLO.LCivR. 6.1. WHEREFORE, Defendants respectfully request the Court grant an extension of time to and including November 23, 2005 to amend pleadings and join additional parties. Dated: November 15, 2005. Respectfully submitted, s/ Kurt Lewis Kurt S. Lewis Lewis Scheid LLC 2300 Fifteenth Street, Suite 320 Denver, CO 80202 Phone: (303) 534-5040 Facsimile: (303) 534-5039 [email protected] ATTORNEYS FOR DEFENDANTS GENERAL STEEL DOMESTIC SALES, LLC GENSTONE ENTERPRISES, LLC & JEFF KNIGHT

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

Document 105

Filed 11/15/2005

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 15th day of November, 2005, I electronically filed the foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME TO AMEND ANSWER 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: 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 Kurt S. Lewis