Netquote Inc. v. Byrd
Filing
38
Joint MOTION For Extension of Time to
Respond to Written Discovery Requests by Plaintiff Netquote Inc., Counter Defendant Netquote Inc.. (Attachments: #
1 Proposed Order (PDF Only))(Williams, Daniel)
Netquote Inc. v. Byrd
Doc. 38
Case 1:07-cv-00630-DME-MEH
Document 38
Filed 06/18/2007
Page 1 of 3
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 07-cv-00630-DME-MEH NETQUOTE INC, a Colorado corporation, Plaint iff, v. BRANDON BYRD, an internet user making use of the IP Addresses 64.136.27.226 and 64.136.26.227, and MOSTCHOICE.COM, INC., a Georgia corporation, Defendants. JOINT MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO WRITTEN DISCOVERY REQUESTS NetQuote, Inc. and MostChoice.com, Inc. (the " arties" respectfully submit this Joint P ) Motion for Enlargement of Time pursuant to Fed. R. Civ. P. 6(b)(1) and D.C. Colo. L. Civ. R. 6.1.D, requesting an enlargement of time within which to respond to written discovery requests. In support of their Motion, the Parties state: 1. Pursuant to D.C. Colo. L. Civ. R. 6.1.D, the undersigned counsel certify that a
copy of this Motion is being served upon their respective clients and all counsel of record.
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Dockets.Justia.com
Case 1:07-cv-00630-DME-MEH
Document 38
Filed 06/18/2007
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2.
The Parties served their respective first sets of interrogatories and requests for
production of documents on May 17, 2007, and their responses and currently due on June 19, 2007.1 3. The Parties are currently gathering the information to give full and complete
responses, and in order to accommodate previously scheduled summer vacations and the press of other business, agree to an enlargement of time to and including July 13, 2007, to respond to the written discovery requests. 4. This is the first request by the Parties for an enlargement of time within which to
respond to the discovery requests. 5. There are no other Court-imposed deadlines that will be affected by this
enlargement of time WHEREFORE, the Parties respectfully request that the Court enter an Order allowing them up to and including July 13, 2007, to finalize and respond to the first sets of interrogatories and requests for production of documents. DATED: June 18, 2007 _s/ David W. Stark_ David W. Stark FAEGRE & BENSON LLP 3200 Wells Fargo Center 1700 Lincoln Street Denver, Colorado 80203 Telephone: (303) 607-3500 Facsimile: (303) 607-3600 E-mail: dstark@faegre.com
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_s/ Ryan L. Isenberg__ Ryan L. Isenberg ISENBERG & HEWITT, P.C. 7000 Peachtree Dunwoody Road, Bldg 15, Suite 100 At lanta, Georgia 30328 Telephone: (770) 351-4400 Facsimile: (678) 990-7737 E-mail: ryan@isenberg-hewitt.com
Plaintiff previously had served discovery requests on Defendant Byrd and Defendant Byrd has responded to those requests. 2
Case 1:07-cv-00630-DME-MEH
Document 38
Filed 06/18/2007
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Daniel D. Williams FAEGRE & BENSON LLP 1900 Fifteenth Street Boulder, Colorado 80302 Telephone: (303) 447-7700 Facsimile: (303) 447-7800 E-mail: dwilliams@faegre.co m Counsel for Plaintiff
Tracy L. Ashmore Rachel L. Eichenbaum HOLME ROBERTS & OWENS LLP 4400 Wells Fargo Center 1700 Lincoln Street Denver, Colorado 80203 Telephone: (303) 866-0323 Facsimile: (303) 866-0200 E-mail: rachel.eichenbaum@hro.com Counsel for Defendants
CERTIFICATE OF SERVICE (NON CM/ECF PARTICIPANTS) I hereby certify that on June 18, 2007, I served the foregoing JOINT MOTION FOR ENLARGEMENT OF TIME via U.S. mail, postage paid, addressed to the following persons at the given addresses: Craig Shine NetQuote, Inc. 1860 Blake St. Denver, CO 80202 MostChoice.Co m 5600 Roswell Road, Suite 275 North At lanta, GA 30342 Brandon Byrd 147 Angus Trail At lanta, GA 30328 s/Cecil A. Kennedy
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