Free Motion for Extension of Time to File Response/Reply - District Court of Colorado - Colorado

Case 1:03-cv-01364-JLK

Document 74

Filed 02/21/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-1364-JLK SCOT HOLLONBECK, JOSE ANTONIO INIGUEZ, JACOB WALTER JUNG HO HEILVEIL, and VIE SPORTS MARKETING, INC., a Georgia corporation, Plaintiffs, v. UNITED STATES OLYMPIC COMMITTEE, a federally-chartered corporation, and U.S. PARALYMPICS, INC., f/k/a UNITED STATES PARALYMPIC CORPORATION, a Colorado non-profit corporation, Defendants.

PLAINTIFF VIE SPORTS MARKETING, INC.'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO REPLY TO COUNTERCLAIM

Plaintiff Vie Sports Marketing, Inc. ("Vie"), by and through their attorneys Fox & Robertson, hereby submit their Unopposed Motion for Extension of Time to Reply to Counterclaim ("Plaintiff's Motion"). Certificate of Compliance with D.C. Colo. L.R. 7.1(A) On February 21, 2007 Plaintiff's counsel conferred with Defendant's counsel Jeffrey S. George who stated that he did not oppose a seven-day extension of time to reply to the counterclaim.

Case 1:03-cv-01364-JLK

Document 74

Filed 02/21/2007

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1.

On February 2, 2007, Defendants filed an Answer to Plaintiffs' Amended

Complaint, in which Defendant U.S. Paralympics, Inc. ("Paralympics") asserted a counterclaim against Plaintiff Vie. (Answer at 37.) 2. Plaintiff has 20 days to reply to the counterclaim. Fed. R. Civ. P. 12(a)(2).

Therefore, Plaintiff would otherwise have up to, and including, February 22, 2007, to file a reply to Defendant's counterclaim. 3. Defendant Paralympics has agreed to not more than a seven-day extension for

Plaintiff to reply to the counterclaim. Therefore, Plaintiff seeks a seven-day extension to file a reply to Defendant Paralympics' counterclaim. WHEREFORE, Plaintiff Vie respectfully requests this Court grant Plaintiff's Motion and allow Plaintiff to submit its Reply to Defendant's Counterclaim by March 1, 2007. Dated: February 21, 2007 Respectfully submitted, FOX & ROBERTSON, P.C.

s/ Ari Krichiver Ari Krichiver Amy F. Robertson Timothy P. Fox Fox & Robertson, P.C. 910 - 16th Street, Suite 610 Denver, CO 80202 303.595.9700 Attorneys for Plaintiffs

Kevin W. Williams Legal Program Director Colorado Cross-Disability Coalition 655 Broadway, Suite 775 Denver, CO 80203 303.839.1775 Dated: February 21, 2007

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Case 1:03-cv-01364-JLK

Document 74

Filed 02/21/2007

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Certificate of Service I hereby certify that on February 21, 2007, 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: John William Cook [email protected] Jeffrey S. George [email protected] Amy F. Robertson [email protected] Anne Hall Turner [email protected] Kevin William Williams [email protected]

And a copy was mailed by first class mail postage prepaid to: Christopher Todd Handman Hogan & Hartson, LLP-DC 555 Thirteenth Street, N.W. Washington, DC 20004-1109

s/ Ari Krichiver Ari Krichiver Fox & Robertson, P.C. 910 - 16th Street, Suite 610 Denver, CO 80202 303.595.9700 Email: [email protected]