Bray et al v QFA Royalties

Filing 26

Stipulated MOTION to Expedite Discovery Schedule and Set Briefing Schedule and Extend Deadlines by Defendant QFA Royalties LLC. (Attachments: # 1 Proposed Order (PDF Only))(MacPhee, Leonard)

Bray et al v QFA Royalties

Doc. 26

Case 1:06-cv-02528-JLK

Document 26

Filed 01/10/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 06-cv-02528-JLK-CBS CHRIS BRAY, et al. Plaintiffs, v. QFA ROYALTIES LLC, Defendant. STIPULATED MOTION TO SET DISCOVERY SCHEDULE ON EXPEDITED BASIS AND SET BRIEFING SCHEDULE AND EXTEND DEADLINES Defendant QFA Royalties LLC ("Quiznos"), by and through its attorneys, hereby submits this Stipulated Motion to Set Discovery Schedule on Expedited Basis and Set Briefing Schedule and Extend Deadlines as follows: CERTIFICATE OF COMPLIANCE WITH L.R. 7.1 Counsel for Quiznos has conferred with counsel for Plaintiffs, Gregory Stross. Mr. Stross stated that Plaintiffs concur with the relief requested herein. 1. Plaintiffs initiated this action on or about December 15, 2006 by filing a

complaint and motion for preliminary injunction. 2. 3. On December 22, 2006, all parties appeared at a status conference. At the status conference, the Court set a hearing on Plaintiffs' motion for a

preliminary injunction for February 12, 13 and 14, 2007. The Court also requested that the parties coordinate with each other with respect to expedited discovery and related issues.

33668-0077/LEGAL12953307.1

Dockets.Justia.com

Case 1:06-cv-02528-JLK

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Filed 01/10/2007

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4.

The parties are currently in the process of conducting discovery and depositions

and have agreed to the following schedule for that expedited discovery relating to the issues for the hearing on the preliminary injunction. The parties have agreed that written discovery will be served no later than January 11, 2007 and that responses will be provided no later than January 22, 2007. Further, depositions will occur in Denver at mutually agreed times on the days of January 24-26, 29 and 30, 2007. 5. Further, the parties have agreed Quiznos answer or other response to the

Complaint will be due 15 days following the decision on the motion for preliminary injunction. 6. Further, the parties have agreed to the following briefing schedule with respect to

the Motion for Preliminary Injunction: Quiznos will file a Response to Plaintiffs' Motion for Preliminary Injunction on or before February 1, 2007; and Plaintiffs may file a Reply to Quiznos' Response on or before February 7, 2007. WHEREFORE, the parties respectfully request that the Court enter an order providing (i) that written discovery will be served no later than January 11, 2007 and responses will be provided no later than January 22, 2007; (ii) that depositions may occur in Denver at mutually agreed upon times on the days of January 24-26, 29 and 30, 2007; (iii) that Quiznos' answer or other response to Plaintiffs' Complaint will be due 15 days following the Court's ruling on Plaintiffs' Motion for Preliminary Injunction; and (iv) that Quiznos' Response to Plaintiffs' Motion for Preliminary Injunction is due on or before February 1, 2007 and Plaintiffs may file a Reply to Quiznos' Response on or before February 7, 2007.

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Dated this 10th day of January, 2007. Respectfully submitted, s/ Leonard H. MacPhee Leonard H. MacPhee Attorney for Defendant Perkins Coie LLP 1899 Wynkoop Street, Suite 700 Denver, CO 80202 Telephone: [phone] Facsimile: [phone] Email: [e-mail]

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Case 1:06-cv-02528-JLK

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Filed 01/10/2007

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CERTIFICATE OF SERVICE I hereby certify that on January 10, 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 email addresses:
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Fredric Adam Cohen [e-mail] Justin M. Klein [e-mail],[e-mail],joanne @marksklein.com Gregory Robert Stross [e-mail]

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s/ Leonard H. MacPhee Leonard H. MacPhee Attorney for Defendant Perkins Coie LLP 1899 Wynkoop Street, Suite 700 Denver, CO 80202 Telephone: [phone] Facsimile: [phone] Email: [e-mail]

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