Video Professor, Inc. v. Amazon.com, Inc.
Unopposed MOTION to Amend/Correct/Modify 20 Scheduling Order by Defendant Amazon.com, Inc.. (Attachments: # 1 Proposed Order (PDF Only))(Levy, Marc)
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 1:09-CV-00636-REB-KLM VIDEO PROFESSOR, INC. Plaintiff, v. AMAZON.COM, INC. Defendant. ______________________________________________________________________________ UNOPPOSED MOTION TO AMEND SCHEDULING ORDER ______________________________________________________________________________ Defendant Amazon.com, Inc., through its undersigned counsel, upon good cause shown, and with the agreement of Plaintiff Video Professor, Inc., moves to amend the Scheduling Order entered in this case. In support thereof, Amazon states as follows: CERTIFICATE OF CONSULTATION Pursuant to D.C.COLO.LCivR 7.1(A), the Parties met and conferred regarding the subject matter of this Motion. Video Professor agrees to the relief requested herein. 1. On July 9, 2009 (Docket No. 20), the Court entered a Scheduling Order to govern
conduct of pretrial activity in this case. That Order provides that the Parties will supplement the " ndisputed Facts"section by amendment " ithin 30 days"(or August 10, 2009). Trial is not set U w to occur in this case until April 26, 2010. 2. The Parties have exchanged written proposals to supplement the " ndisputed U
Facts"section but require additional time to attempt to negotiate a mutually acceptable list to
submit to the Court. Specifically, it is requested that the Parties be given until August 21, 2009 to submit an amendment supplementing the " ndisputed facts"section of the Scheduling Order. u 3. Good cause exists for such an extension to allow the Parties additional time to
remove certain facts from dispute and thus facilitate the efficient disposition of this matter. 4. The Parties have not requested or obtained any previous extension of the pretrial
deadlines in this case. The Parties do not seek this brief extension for any improper purpose and no party will be prejudiced by the requested stay. 5. Pursuant to D.C.COLO.LCivR 6.1(D), a copy of this Motion has been served on
Amazon' client representative, and all counsel of record. s WHEREFORE, Amazon requests, upon good cause shown, that the Court amend the Scheduling Order and grant an eleven (11) day extension of time, up to and including Friday, August 21, 2009, of the deadline for submission of an amendment supplementing the " ndisputed U Facts"section. Dated August 5, 2009 /s/ Marc C. Levy (original signature in file) Marc C. Levy (Bar No. 40000) firstname.lastname@example.org m Faegre & Benson LLP 3200 Wells Fargo Center 1700 Lincoln Street Denver, CO 80203-4532 Phone: 303-607-3500 Fax: 303-607-3600 ATTORNEY FOR DEFENDANT AMAZON.COM, INC.
CERTIFICATE OF SERVICE I hereby certify that on August 5, 2009, I electronically filed the UNOPPOSED MOTION TO AMEND SCHEDULING ORDER with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following persons at the given email addresses: Gregory C. Smith Fairfield & Woods, P.C. 1700 Lincoln Street, Suite 2400 Denver, CO 80203 Email: email@example.com /s/Lori E. True
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