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

Case 1:01-cv-00600-JLK-MEH

Document 71

Filed 09/08/2006

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 01-cv-0600-JLK-MEH GO PRO, LTD., a Georgia limited liability company, Plaintiff, v. RIVER GRAPHICS, INC., a Colorado corporation, Defendant.

STIPULATED MOTION FOR EXTENSION OF TIME TO FILE DISMISSAL PAPERS

Pursuant to D.C.COLO.LCivR 6.1, Plaintiff Go Pro, Ltd. and Defendant River Graphics, Inc. (collectively "the Parties") by and through undersigned counsel, hereby move for an extension of time to file dismissal papers as required by the Court's August 31, 2006 Minute Entry based on good cause. As grounds therefor, the Parties state as follows: 1. On August 30, 2006, a settlement conference was held and the Parties reached a

tentative settlement agreement. In light of this tentative agreement, the Court issued a Minute Entry on August 31, 2006, requiring the Parties to file dismissal papers by September 8, 2006. 2. Since the August 30, 2006 Settlement Conference, the Parties have been diligent

in actively drafting and negotiating a final settlement agreement. Additional time is needed to finalize and execute the Settlement Agreement.

Case 1:01-cv-00600-JLK-MEH

Document 71

Filed 09/08/2006

Page 2 of 3

3.

In light of the foregoing, the Parties request a minimal seven (7) calendar day

extension of time up and to September 15, 2006 to file dismissal papers. No party will be prejudiced by the entry of such extension of time. 4. Pursuant to D.C.COLO.LCivR 6.1D, all parties and counsel of record have been

served with a copy of this Motion and accompanying Order. WHEREFORE, the Parties respectfully request a seven (7) calendar day extension of time up to, and including, September 15, 2006 to file dismissal papers. A proposed Order is attached for the Court's convenience. Respectfully submitted this 8th day of September, 2006.

s/ Paul S. Cha Robert R. Brunelli, Esq. [email protected] Paul S. Cha, Esq. [email protected] SHERIDAN ROSS P.C. 1560 Broadway, Suite 1200 Denver, Colorado 80202-5141 Telephone: 303-863-9700 Facsimile: 303-863-0223 E-mail: [email protected] ATTORNEYS FOR PLAINTIFF GO PRO, LTD.

s/ William P. Boyle (with permission) Franklin D. Patterson, Esq. [email protected] William P. Boyle, Esq. [email protected] PATTERSON, NUSS & SEYMOUR, P.C. 304 Inverness Way South, Suite 305 Englewood, Colorado 80112 Telephone: 303-741-4539 Facsimile: 303-741-5043 ATTORNEYS FOR DEFENDANT RIVER GRAPHICS, INC.

2

Case 1:01-cv-00600-JLK-MEH

Document 71

Filed 09/08/2006

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 8th day of September, 2006, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses:

and served the following via U.S. Mail, first-class postage prepaid to: Go Pro Ltd. 2925 Northeast Parkway Atlanta, Georgia 30360 PLAINTIFF River Graphics, Inc. 3743 South Inca Englewood, Colorado 80110 DEFENDANT s/ Kristin M. Heil Kristin M. Heil Assistant to Paul S. Cha SHERIDAN ROSS P.C. 1560 Broadway, Suite 1200 Denver, Colorado 80202-5141 Telephone: 303-863-9700 Facsimile: 303-863-0223 E-mail: [email protected] [email protected]
J:\4707\-1\PLEADINGS\STIP MTN FOR EXTENSION OF TIME.doc

3