Free Motion for Summary Judgment - District Court of Colorado - Colorado

Case 1:01-cv-00275-JLK

Document 970

Filed 07/10/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 01-cv-0275-JLK DOMINICK PAOLONI, et al., Plaintiffs, vs. DONALD I. GOLDSTEIN, et al., Defendants, and NBSA, LLC, et al., Relief Defendants. ______________________________________________________________________________ SUPPLEMENT TO MOTION FOR SUMMARY JUDGMENT AGAINST JOSEPH IERACITANO AND BLUE PAPER INC. ______________________________________________________________________________ COME NOW the Plaintiffs, by and through their attorneys, Dill Dill Carr Stonbraker & Hutchings, P.C., and herein supplement their Motion for Summary Judgment against Joseph Ieracitano and Blue Paper Inc. as follows: 1. On June 16, 2008 Plaintiffs filed a Motion for Summary Judgment against Joseph

Ieracitano and Blue Paper Inc. (Docket entry #965) together with supporting pleadings of; a. Memorandum in Support of Motion for Summary Judgment against Joseph Ieracitano and Blue Paper Inc. (Docket entry #966); b. Statement of Undisputed Facts (Docket entry #967); c. Affidavit of Rocky K. Smith (Docket entry #967-2), and; d. Exhibits in Support of Motion for Summary Judgment against Joseph Ieracitano and Blue Paper Inc. (Docket entry #968).

Case 1:01-cv-00275-JLK

Document 970

Filed 07/10/2008

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2.

On June 20, 2008 this Court entered a Minute Order (Docket entry #969) in which

the Court Ordered Joseph Ieracitano and Blue Paper Inc. to respond to Plaintiffs' Motion for Summary Judgment against Joseph Ieracitano and Blue Paper Inc. on or before July 9, 2008. Plaintiffs' were given until July 28, 2008 to file a reply in response to any response filed by Joseph Ieracitano and Blue Paper Inc. 3. Joseph Ieracitano and Blue Paper Inc. have failed to file any response to

Plaintiffs' Motion for Summary Judgment against Joseph Ieracitano and Blue Paper Inc. as order by this Court. 4. Plaintiffs' Motion for Summary Judgment against Joseph Ieracitano and Blue

Paper Inc. is now ripe for decision by this Court. 5. In accordance with the pleadings and affidavits presently on file with the Court,

and pursuant to applicable law, Plaintiffs' are entitled to Summary Judgment against Joseph Ieracitano and Blue Paper Inc. as requested in their Motion for Summary Judgment against Joseph Ieracitano and Blue Paper Inc. DATED this 10th day of July, 2008

Respectfully submitted, DILL DILL CARR STONBRAKER & HUTCHINGS, P.C.

/s/John A. Hutchings John A. Hutchings 455 Sherman Street, Suite 300 Denver, Colorado 80203 Telephone: (303) 777-3737 Facsimile: (303) 777-3823 E-mail: [email protected] ATTORNEY FOR PLAINTIFFS

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Case 1:01-cv-00275-JLK

Document 970

Filed 07/10/2008

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CERTIFICATE OF SERVICE I hereby certify that on July 10th, 2008 I electronically filed the foregoing SUPPLEMENT TO MOTION FOR SUMMARY JUDGMENT AGAINST JOSEPH IERACITANO AND BLUE PAPER INC. with the Clerk of Court using CM/ECF System, which will send notification of such filing to the following e-mail addresses: [email protected] [email protected] [email protected] [email protected]

and I hereby certify that I have mailed the SUPPLEMENT TO MOTION FOR SUMMARY JUDGMENT AGAINST JOSEPH IERACITANO AND BLUE PAPER to the following non-CM/ECF participants by depositing same in the United States mail, postage prepaid, addressed to the following on the 10th day of July, 2008: Akerman Senterfitt 350 East Las Olas Blvd., #1600 Ft. Lauderdale, FL 33301 Gary Hoskie Professional Consultants & Managers, Inc. P.O. Box 644320 Vero Beach, FL 32954-4320 Mr. Isadore Cohen 1920 East Hallandale Blvd., #626 Hallandale, FL 33009 Mr. Joseph Ieracitano Blue Paper, Inc. 2608-10 North Ocean Boulevard Pompano Beach, FL 33062

/s/ Juliann Pettaway

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