Bray et al v QFA Royalties

Filing 62

Unopposed MOTION for Extension of Time to File Answer re 1 Complaint,, or Otherwise Respond by Defendant QFA Royalties LLC. (Attachments: # 1 Proposed Order (PDF Only))(MacPhee, Leonard)

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Bray et al v QFA Royalties Doc. 62 Case 1:06-cv-02528-JLK Document 62 Filed 05/18/2007 Page 1 of 3 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 06-cv-02528-JLK CHRIS BRAY, SABINE BRAY, TRAINING PROS INC., BRAD FIX, JAN FIX, BJ AND F LLC, HAKIM ABID, and ALLISON ABID, Plaintiffs, v. QFA ROYALTIES LLC, Defendant. UNOPPOSED MOTION FOR EXTENSION OF TIME TO ANSWER OR OTHERWISE RESPOND TO COMPLAINT Defendant QFA Royalties LLC ("Quiznos"), by and through its attorneys, hereby submits this Unopposed Motion for Extension of Time to Answer or Otherwise Respond to Complaint 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 do not oppose the relief requested herein. 1. Plaintiffs initiated this action on or about December 15, 2006 by filing a Complaint and Motion for Preliminary Injunction. 33668-0077/LEGAL13248171.1 Dockets.Justia.com Case 1:06-cv-02528-JLK Document 62 Filed 05/18/2007 Page 2 of 3 2. A two-day hearing on Plaintiffs' Motion for Preliminary Injunction was held on February 12 and 13, 2007. 3. Pursuant to the pre-hearing schedule agreed upon and ordered by the court [Docs 26 and 27], Quiznos' answer or other response to the Complaint was due 15 days following the decision on the Motion for Preliminary Injunction. 4. 5. 6. On May 3, 2007 the Court enter its Order on Motion for Preliminary Injunction. Quiznos anticipates filing a notice of appeal of this Court's Order. The parties contemporaneously herewith are filing a joint status report apprising the Court of their proposed course of action during the pendency of the appeal which will include a request that the Court stay this matter pending the appeal process. 7. Accordingly, Quiznos requests that the Court extend the deadline by which to answer or otherwise respond to the Complaint for 21 days or until June 7, 2007. And, to the extent this case is stayed pending appeal, will request that this deadline be stayed as well. WHEREFORE, Quiznos respectfully requests that the Court enter an order extending the time in which Quiznos' answer or other response to the complaint be extended for 21 days or until June 7, 2007. 33668-0077/LEGAL13248171.1 -2- Case 1:06-cv-02528-JLK Document 62 Filed 05/18/2007 Page 3 of 3 Dated this 18th day of May, 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: (303) 291-2300 Facsimile: (303) 291-2400 Email: lmacphee@perkinscoie.com CERTIFICATE OF SERVICE I hereby certify that on May 18, 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: Fredric Adam Cohen fredric.cohen@chengcohen.com Justin M. Klein justin@marksklein.com,david@marksklein.com,joanne @marksklein.com Gregory Robert Stross gstross@earthlink.net s/ Leonard H. MacPhee Leonard H. MacPhee Attorney for Defendant Perkins Coie LLP 1899 Wynkoop Street, Suite 700 Denver, CO 80202 Telephone: (303) 291-2300 Facsimile: (303) 291-2400 Email: lmacphee@perkinscoie.com 33668-0077/LEGAL13248171.1 -3-

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