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

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

Document 88

Filed 10/14/2005

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IN THE UNITED STATES DISTRICT COURT DISTRICT OF COLORADO

Civil Action No. 04-cv-617-LTB-BNB POLYROCK TECHNOLOGIES, LLC, a Colorado limited liability company, Plaintiff, v. GENERAL STEEL DOMESTIC SALES, LLC, et al., Defendants.

JOINT UNOPPOSED MOTION TO EXTEND DEADLINE TO AMEND PLEADINGS

Plaintiff PolyRock Technologies, LLC and defendants General Steel Domestic Sales, LLC; Genstone Enterprises, LLC; and Jeff Knight jointly move the Court to extend the deadline to amend pleadings and join parties to and including November 16, 2005. Defendant Charles Demarest is not joining in this motion, but counsel for the moving parties are authorized to state that Mr. Demarest does not oppose the relief requested herein. As grounds for this motion, the moving parties state: 1. Pursuant to the Scheduling Order dated August 18, 2005, the deadline for the joinder of parties and amendment of pleadings is currently October 15, 2005 (which rolls over to October 17 because October 15 is a Saturday). 2. The moving parties agree that due to the current stage of discovery, it is appropriate to extend the deadline to join parties and amend pleadings 30 days, to November 16, 2005.

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

Document 88

Filed 10/14/2005

Page 2 of 3

Extension of this deadline will not affect any other pre-trial deadline or the trial date in this case, and will not prejudice any party. 3. The moving parties accordingly request the Court to enter an Order extending the deadline to amend the pleadings and join additional parties to November 16, 2005.

DATED: October 14, 2005.

Respectfully submitted:

s/John A. DeSisto John A. DeSisto, FEATHERSTONE DESISTO LLP 600 17th Street, #2400 Denver, CO 80202 Telephone: 303 626-7100 Facsimile: 303 626-7101 e-mail: [email protected] Attorney for Plaintiff PolyRock Technologies, LLC

s/Kurt Lewis Kurt S. Lewis LEWIS SCHEID LLC 2300 15th Street #320 Denver, CO 80202 Telephone: 303 534-5040 Facsimile: e-mail: Attorney for Defendants General Steel Domestic Sales, LLC; Genstone Enterprises, LLC and Jeff Knight;

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

Document 88

Filed 10/14/2005

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on October 14, 2005, 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: Susan M. Hargleroad Pendleton, Friedberg, Wilson & Hennessey, P.C. [email protected] Kurt S. Lewis Lewis Scheid LLC [email protected]

s/ John A. DeSisto

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