Anderson v. J.P. Morgan Chase & Co. et al

Filing 7

ORDER Granting Unopposed Motion for Extension of Time to Answer or Otherwise Respond to Plaintiff's Amended Complaint, signed by Denver County, District Court Judge, R. Michael Mullins, on 7/13/11. J.P. Morgan Chase & Co. answer due 7/25/2011. (lyg, )

GRANTED

Movant shall serve copies of this ORDER on
any pro se parties, pursuant to CRCP 5, and
file a certificate of service with the Court
within 10 days.

DISTRICT COURT, CITYDated:COUNTY OF DENVER,
AND Jul 13, 2011
COLORADO
Court Address:

Plaintiff:

Denver City & County Building
1437 Bannock Street
Denver, Colorado 80202

R. Michael Mullins
District Court Judge
DATE OF ORDER INDICATED ON ATTACHMENT

EFILED Document
CO Denver County District Court 2nd JD
Filing Date: Jul 13 2011 2:31PM MDT
Filing ID: 38674987
Review Clerk: Patricia Garcia

KAREN ANDERSON

v.
Defendants: J.P. MORGAN CHASE & CO. a/k/a J.P.
MORGAN CHASE AND COMPANY, its
Known and Unknown Partners, Contractors,
Subcontractors, Successors, Heirs and Assigns;
DIEBOLD, INCORPORATED, its Known and
Unknown Partners, Contractors,
Case Number: 2011cv2381
Subcontractors, Successors, Heirs and Assigns;
ALL MAINTENANCE COMPANIES
Div: 275
KNOWN and UNKNOWN, PARTNERS,
CONTRACTORS, SUBCONTRACTORS,
SUCCESSORS, HEIRS AND ASSIGNS; JOHN
DOE and JANE DOE, WHOSE TRUE
IDENTIES ARE UNKNOWN.
Attorneys for Defendant JPMorgan Chase Bank, N.A.:
Mark C. Willis, #31025
Kelly S. Kilgore, #38097
Blair E. Kanis, #41654
KUTAK ROCK LLP
1801 California Street Suite 3100
Denver, Colorado 80202
Telephone: [phone]
Facsimile: 303-292-7799
E-Mail: [e-mail]
[e-mail]
[e-mail]

UNOPPOSED MOTION FOR EXTENSION OF TIME TO ANSWER OR OTHERWISE
RESPOND TO PLAINTIFF’S AMENDED COMPLAINT
Defendant JPMorgan Chase Bank, N.A., incorrectly named in Plaintiff’s Amended
Complaint as J.P. Morgan Chase & Co. a/k/a J.P. Morgan Chase and Company (“Chase”), by
and through its attorneys Kutak Rock LLP, hereby submits the following Unopposed Motion for
4846-5687-4762.1

1

Extension of Time to Answer or Otherwise Respond to Plaintiff’s Amended Complaint and, in
support thereof, states as follows:
1.
Pursuant to C.R.C.P. 121 § 1-15(8), the undersigned hereby certifies that she has
conferred with Plaintiff’s counsel, Geoffrey S. Gulinson, regarding this Motion. Mr. Gulinson
has advised that Plaintiff does not object to the relief requested herein.
2.
Plaintiff filed her Amended Complaint and Jury Demand (the “Amended
Complaint”) on June 3, 2011. On June 21, 2011, Plaintiff served a Summons and a copy of the
Amended Complaint on Chase. Pursuant to C.R.C.P. 6 and 12, Chase’s response to Plaintiff’s
Amended Complaint is due on or before July 11, 2011.
3.
Kutak Rock LLP was recently engaged to represent Chase in this matter. In order
for counsel for Chase to complete its investigation of this matter and properly prepare an answer
or otherwise respond to Plaintiff’s Amended Complaint pursuant to C.R.C.P. 12(b), Chase
requires a brief extension of time through and including July 25, 2011 to respond to the
Amended Complaint.
4.

No parties to this action will be prejudiced by this brief extension.

5.
Pursuant to C.R.C.P. 121(c) § 1-11, a certificate of service is attached hereto
indicating that Chase has been served with a copy of this Motion.
WHEREFORE JPMorgan Chase Bank, N.A., respectfully requests that the Court enter an
Order, in the form submitted herewith, granting it an extension of time through and including
July 25, 2011 to answer or otherwise respond to Plaintiff’s Amended Complaint.
Respectfully submitted this 11th day of July, 2011.
KUTAK ROCK LLP
By: s/ Blair E. Kanis
Blair E. Kanis, #41654
Attorneys For Defendant JPMorgan Chase
Bank, N.A.

4846-5687-4762.1

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CERTIFICATE OF SERVICE
This is to certify that on this 11th day of July, 2011, the foregoing was transmitted via the
Internet to the Court-authorized service provider for electronic and/or other service to:
Geoffrey S. Gulinson & Associates, P.C.
4155 East Jewell Avenue, Suite 402
Denver, CO 80222
[e-mail]

Michele Cerullo McAvoy, Esq.
JPMorgan Chase
194 Wood Avenue South, 2nd Floor
Iselin, NJ 08830

s/ Sandra L. Orvis

In accordance with C.R.C.P. 121, §1-26(9), a printed copy of this document
with original signatures is being maintained by the filing party and will be
made available for inspection by other parties or the court upon request.

4846-5687-4762.1

3

Court: CO Denver County District Court 2nd JD
Judge: Ronald M Mullins
File & Serve
Transaction ID: 38627052
Current Date: Jul 13, 2011
Case Number: 2011CV2381
Case Name: ANDERSON, KAREN vs. JP MORGAN CHASE & CO et al

Court Authorizer
Comments:
THE COURT, having reviewed Defendant JPMorgan Chase Bank, N.A.’s (“Chase”) Unopposed Motion for
Extension of Time to Answer or Otherwise Respond to Plaintiff’s Amended Complaint, and being fully advised
in the premises and good cause shown therefor, HEREBY
ORDERS that the Motion shall be and hereby is GRANTED. Chase shall have through and including July 25,
2011, to answer or otherwise respond to Plaintiff’s Amended Complaint.
/s/ Judge Ronald M Mullins