Netquote Inc. v. Byrd - Document No. 69

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Unopposed MOTION For Extension of Time to Submit Expert Reports by Counter Defendants Netquote Inc., Netquote Inc., Plaintiff Netquote Inc.. (Attachments: # 1 Proposed Order (PDF Only))(Stark, David) 1:2007cv00630 Colorado District Court

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Netquote Inc. v. Byrd

Doc. 69

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

Document 69

Filed 08/17/2007

Page 1 of 4

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 07-cv-00630-DME-MEH NETQUOTE INC, a Colorado corporation, Plaintiff, 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 SUBMIT EXPERT REPORTS

NetQuote, Inc. (“ NetQuote” respectfully moves for an extension of time to submit its ) opening expert report(s). In support of its motion, it states as follows: 1. NetQuote is seeking information concerning disgorgement damages from

MostChoice but has not yet received it. The parties had a telephonic status conference with the Court to attempt to resolve this discovery dispute and are continuing to try to resolve it without resort to a motion to compel. 2. Until MostChoice produces the disgorgement damages information, NetQuote’ s

damages expert cannot complete his expert report. 3. Initial expert reports in this matter currently are required to be exchanged on

September 6, 2007.

Dockets.Justia.com

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

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4.

For the foregoing reason, NetQuote requests an extension until 30 days after the

disgorgement damages information is provided for it to provide Defendants with its initial expert report(s). 5. Pursuant to D.C. Colo. L. Civ. R. 7.1.A, NetQuote states that it raised this request

for an extension at the Settlement Conference conducted by the Court on August 10, 2007. At the Settlement Conference, Magistrate Judge Hegarty informed undersigned counsel that the Defendants do not oppose this request. 6. Pursuant to D.C. Colo. L. Civ. R. 6.1.D, undersigned counsel certifies that a copy

of this Motion is being served upon NetQuote. 7. reports. WHEREFORE, NetQuote respectfully requests that the Court enter an order re-setting the deadline for NetQuote to provide its initial expert report(s) to 30 days after MostChoice produces the disgorgement damages information NetQuote seeks in its Interrogatory No. 10. This is the first request by NetQuote for an enlargement of time to submit expert

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Dated: August 23, 2007

Respectfully submitted,

_/s David W. Stark_______ David W. Stark FAEGRE & BENSON LLP 3200 Wells Fargo Center 1700 Lincoln Street Denver, Colorado 80203 Tel: (303) 607-3500 / Fax: (303) 607-3600 E-mail: [email protected] Daniel D. Williams Teresa Taylor Tate FAEGRE & BENSON LLP 1900 Fifteenth Street Boulder, Colorado 80302 Tel: (303) 447-7700 / Fax: (303) 447-7800 E-mail: [email protected] [email protected]

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Filed 08/17/2007

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CERTIFICATE OF SERVICE I hereby certify that on August 17, 2007, I served the foregoing UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE EXPERT REPORTS was served via CM/ECF filing on: Ryan L. Isenberg, Esq. ISENBERG & HEWITT, P.C. 7000 Peachtree Dunwoody Road, Bldg 15, Suite 100 Atlanta, GA 30328 [email protected]

and was served 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 s/_Daniel D. Williams______

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