Video Professor, Inc. v. Amazon.com, Inc.

Filing 11

First MOTION to Reset 5 Scheduling/Planning Conference by Plaintiff Video Professor, Inc.. (Smith, Gregory) Modified on 5/15/2009 to create linkage to the Scheduling Conference (sah2, ).

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 09-cv-00636 -REM-KLM
VIDEO PROFESSOR, INC., a Colorado corporation, Plaintiff, V. AMAZON.COM, INC., a Delaware corporation, Defendant.

UNOPPOSED MOTION TO RESCHEDULE SCHEDULING/PLANNING CONFERENCE AND RELATED DEADLINES

Video Professor, Inc., by and through its counsel, Fairfield and Woods, P.C., hereby moves to reschedule the Scheduling/Planning Conference and Related Deadlines for a date later than July 7, 2009. In support of this unopposed Motion, Plaintiff states as follows: Certification Pursuant to D.C.COLO.LCivR 7.1 Undersigned certifies that, pursuant to D.C.COLO.LCivR 7. 1, he has conferred with counsel for Defendant who indicated that Defendant does not oppose and, in fact, joins in the instant request to reschedule the upcoming conference. 1. Plaintiff initiated this action on or about March 24, 2009, and served Defendant

with the Summons and Complaint shortly thereafter. 2. An Order setting the Scheduling/Planning Conference was issued on or about

March 24, 2009, and a Scheduling/Planning Conference is currently set for May 26, 2009, at 10:30 a.m.

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3. 4.

The parties have been in settlement negotiations related to this matter. As part of these negotiations, Plaintiff consented to Defendant's request for

additional time to file its Answer or otherwise respond to the Complaint. Defendant's Answer is currently due on May 15, 2009. 5. 6. 7. This request is not made for dilatory purposes. This is the first request to reschedule the Scheduling/Planning Conference. No party will be prejudiced by the Court granting the relief sought herein. Dates Parties Are Not Available 8. Defendant's counsel has advised that he will be unavailable from June 12-21,

2009, and from June 30-July 1, 2009, and would prefer to reschedule the conference to the first available date after July 2, 2009.

9. 23, 2009.

Plaintiff's counsel is not available June 2, 18, 19 and 26, 2009, and July 2-7, and

WHEREFORE, Plaintiff respectfully requests that the Court enter an Order rescheduling the Scheduling/Planning Conference and related deadlines, for a date after July 7, 2009. Dated this 14`h day of May, 2009.

s/ Grezory C. Smith Gregory C. Smith Fairfield and Woods, PC

1700 Lincoln Street, Suite 2400 Denver, CO 80203
Telephone: [phone] FAX: [phone] Email: [e-mail]

ATTORNEYS FOR PLAINTIFF

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CERTIFICATE OF SERVICE
I hereby certify that on the 14th day of May, 2009, a true and correct copy of the foregoing UNOPPOSED MOTION TO RESCHEDULE SCHEDULING/PLANNING CONFERENCE was served via CM/ECF and/or US Mail, as follows to: Marc C. Levy Faegre & Benson LLP 1700 Lincoln Street, Suite 3200 Denver , Colorado 80203 fae re.com Email: mle VIA U.S. Mail Video Professor, Inc. 12055 West 2nd Place Lakewood, CO 80228 s/ Julie K. Boling Julie K. Boling

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