Netquote Inc. v. Byrd

Filing 43

Netquote Inc. v. Byrd

Doc. 43

Case 1:07-cv-00630-DME-MEH

Document 43

Filed 06/20/2007

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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. UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO MOTION TO DISMISS AND REPLY TO COUNTERCLAIM Plaint iff NetQuote, Inc. (" etQuote" respectfully submits this Unopposed Motion for N ) Enlargement of Time pursuant to Fed. R. Civ. P. 6(b)(1), D.C. Colo. L. Civ. R. 6.1.D, and D.C. Colo. L. Civ. R. 7.1.A , requesting an enlargement of time within which to respond to Defendant MostChoice.Co m, Inc.' Motion to Dismiss and Counterclaim. In support of its Motion, s NetQuote states as follows: 1. Pursuant to D.C. Colo. L. Civ. R. 7.1.A, counsel for NetQuote has conferred with

Ryan Isenberg, counsel for Defendants, and NetQuote is authorized to state that Defendants have no objection to the relief requested in this Motion.

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2.

Pursuant to D.C. Colo. L. Civ. R. 6.1.D, the undersigned counsel certifies that a

copy of this Motion is being served upon its client and all counsel of record. 3.. Defendant MostChoice.com (" ostCho ice" served its Motion to Dismiss for M )

Failure to State a Claim Upon Which Relief Can Be Granted on June 15, 2007, and NetQuote' s response is currently due on July 5, 2007. 4. Defendant MostChoice served its Answer and Counterclaim on June 15, 2007,

and NetQuote' response to the Counterclaim is currently due on July 9, 2007. s 5. In order to accommodate a previously scheduled summer vacation and the press

of other business, the parties agree to an enlargement of time to and including July 16, 2007, for NetQuote to respond to the Motion to Dismiss and to the Counterclaim. 4. This is the first request by the Plaintiff for an enlargement of time within which to

respond to the Motion Dismiss and to the Counterclaim. 5. There are no other Court-imposed deadlines that will be affected by this

enlargement of time.

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WHEREFORE, Plaintiff NetQuote respectfully requests that the Court enter an Order allowing it up to and including July 16, 2007, to file its responses to the Motion to Dismiss and to the Counterclaim. DATED: June 20, 2007 _s/ David W. Stark_ David W. Stark FAEGRE & BENSON LLP 3200 Wells Fargo Center 1700 Lincoln Street Denver, Colorado 80203 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] Daniel D. Williams FAEGRE & BENSON LLP 1900 Fifteenth Street Boulder, Colorado 80302 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] m Counsel for Plaintiff

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CERTIFICATE OF SERVICE I hereby certify that on June 20, 2007, I electronically filed the foregoing UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO MOTION TO DISMISS AND REPLY TO COUNTERCLAIM with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Teresa L. Ashmore, Esq. ([e-mail]) Rachel L. Eichenbaum, Esq. (Rachel.E [e-mail] m) HOLME ROBERTS & OWEN, LLP 1700 Lincoln Street, Suite 4100 Denver, CO 80203 Ryan L. Isenberg, Esq. ([e-mail]) ISENBERG & HEWITT, P.C. 7000 Peachtree Dunwoody Road Bldg. 15, Suite 100 At lanta, Georgia 30328 s/ Cecil A. Kennedy CERTIFICATE OF SERVICE (NON CM/ECF PARTICIPANTS) I hereby certify that on June 20, 2007, I served the foregoing UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO MOTION TO DISMISS AND REPLY TO COUNTERCLAIM 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

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Brandon Byrd 147 Angus Trail At lanta, GA 30328 s/Cecil A. Kennedy

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