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DATE FILED: October 12, 2023 10:55 AM
DISTRICT COURT, EL PASO COUNTY, COLORADO
FILING ID: 7FC07B2051110
270 S. Tejon Street CASE NUMBER: 2023CV31638
Colorado Springs, CO 80903
Plaintiffs: PYRAMID ENTERTAINMENT, LLC, a
Colorado limited liability company; and
BLAIR KRISTY, an individual,
v.
Defendants: xxxxx xxxxxx xxxxxxx, an â–² COURT USE ONLY â–²
individual; xxxxxx xxxxxx xxxxxxxx, an
individual; xxxx xxxxxxxxx, an individual.
Case No. 2023CV31638
Attorneys for Defendant xxxxx xxxxxx xxxxxxx
Eric N. Kibel, #35220 Div. 8
ROBINSON & HENRY, P.C.
7775 East Hampden Avenue, Suite 600
Denver, CO 80231
Telephone: (303) 688-0944
Facsimile: (303) 369-7654
Email: eric.kibel@robinsonandhenry.com
DEFENDANT xxxxx xxxxxxx’S UNOPPOSED MOTION FOR
EXTENSION OF TIME TO FILE RESPONSIVE PLEADING TO THE
VERIFIED COMPLAINT, WITH CERTIFICATE OF CONFERRAL
Defendant xxxxx xxxxxxx, by and through his counsel, Eric N. Kibel of the law firm of
ROBINSON & HENRY, P.C., moves this court for a two-week extension of time, to and including
November 1, 2023, to file a responsive pleading, and as grounds therefore states as follows:
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CERTIFICATE OF CONFERRAL
The undersigned counsel for Defendant xxxxxxx certifies that prior to filing the instant
motion he met and conferred by telephone with Samuel Scheurich, counsel for Plaintiffs,
concerning the relief requested herein and is authorized to advise the court that Plaintiffs do not
oppose this motion.
MOTION FOR EXTENSION OF TIME
Defendant xxxxxxx was served with the summons and complaint in this matter on
September 27, 2023, making his response thereto due on October 18, 2023. Defendant and his
counsel have been diligent in investigating the allegations of the complaint and the facts and
circumstances surrounding extensive online posts of the parties and other individuals which are
alleged to be defamatory by Plaintiffs.
Defendant xxxxxxx requests a brief, two-week extension of time, to and including
November 1, 2023 to file a responsive pleading to the complaint, in order for Defendant and his
counsel to adequately review and digest all the relevant facts and present a well-reasoned and
informed response to the allegations of Plaintiffs’ complaint.
Upon information and belief, the other defendants named in the complaint have not yet
been served. Accordingly, a brief extension of time for Mr. xxxxxxx to file a responsive pleading
will not unduly delay the progress of the litigation, and no party will be prejudiced by a short
extension of time.
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WHEREFORE, Defendant xxxxx xxxxxxx respectfully requests that this court grant him
an extension of time, to and including November 1, 2023, to file a responsive pleading in this
matter.
Respectfully submitted this 12th day of October, 2023.
ROBINSON & HENRY, P.C.
/s/ Eric N. Kibel – signature on file
____________________________________
Eric N. Kibel, #35220
Attorneys for Defendant
xxxxx xxxxxx xxxxxxx
CERTIFICATE OF SERVICE
I certify that on this 12th day of October, 2023, I served a true and correct copy of the
foregoing DEFENDANT xxxxx xxxxxxx’S UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE RESPONSIVE PLEADING TO THE VERIFIED COMPLAINT, WITH
CERTIFICATE OF CONFERRAL on counsel of record for all parties in this matter via electronic
service concurrently with the submission hereof for e-filing via the court’s online filing system.
/s/ Eric N. Kibel – signature on file
____________________________________
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DATE FILED: October 12, 2023 10:55 AM DISTRICT COURT, EL PASO COUNTY, COLORADO FILING ID: 7FC07B2051110 270 S. Tejon Street CASE NUMBER: 2023CV31638 Colorado Springs, CO 80903 Plaintiffs: PYRAMID ENTERTAINMENT, LLC, a Colorado limited liability company; and BLAIR KRISTY, an individual, v. Defendants: xxxxx xxxxxx xxxxxxx, an ▲ COURT USE ONLY ▲ individual; xxxxxx xxxxxx xxxxxxxx, an individual; xxxx xxxxxxxxx, an individual. Case No. 2023CV31638 Attorneys for Defendant xxxxx xxxxxx xxxxxxx Eric N. Kibel, #35220 Div. 8 ROBINSON & HENRY, P.C. 7775 East Hampden Avenue, Suite 600 Denver, CO 80231 Telephone: (303) 688-0944 Facsimile: (303) 369-7654 Email: eric.kibel@robinsonandhenry.com DEFENDANT xxxxx xxxxxxx’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSIVE PLEADING TO THE VERIFIED COMPLAINT, WITH CERTIFICATE OF CONFERRAL Defendant xxxxx xxxxxxx, by and through his counsel, Eric N. Kibel of the law firm of ROBINSON & HENRY, P.C., moves this court for a two-week extension of time, to and including November 1, 2023, to file a responsive pleading, and as grounds therefore states as follows: 1 CERTIFICATE OF CONFERRAL The undersigned counsel for Defendant xxxxxxx certifies that prior to filing the instant motion he met and conferred by telephone with Samuel Scheurich, counsel for Plaintiffs, concerning the relief requested herein and is authorized to advise the court that Plaintiffs do not oppose this motion. MOTION FOR EXTENSION OF TIME Defendant xxxxxxx was served with the summons and complaint in this matter on September 27, 2023, making his response thereto due on October 18, 2023. Defendant and his counsel have been diligent in investigating the allegations of the complaint and the facts and circumstances surrounding extensive online posts of the parties and other individuals which are alleged to be defamatory by Plaintiffs. Defendant xxxxxxx requests a brief, two-week extension of time, to and including November 1, 2023 to file a responsive pleading to the complaint, in order for Defendant and his counsel to adequately review and digest all the relevant facts and present a well-reasoned and informed response to the allegations of Plaintiffs’ complaint. Upon information and belief, the other defendants named in the complaint have not yet been served. Accordingly, a brief extension of time for Mr. xxxxxxx to file a responsive pleading will not unduly delay the progress of the litigation, and no party will be prejudiced by a short extension of time. 2 WHEREFORE, Defendant xxxxx xxxxxxx respectfully requests that this court grant him an extension of time, to and including November 1, 2023, to file a responsive pleading in this matter. Respectfully submitted this 12th day of October, 2023. ROBINSON & HENRY, P.C. /s/ Eric N. Kibel – signature on file ____________________________________ Eric N. Kibel, #35220 Attorneys for Defendant xxxxx xxxxxx xxxxxxx CERTIFICATE OF SERVICE I certify that on this 12th day of October, 2023, I served a true and correct copy of the foregoing DEFENDANT xxxxx xxxxxxx’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSIVE PLEADING TO THE VERIFIED COMPLAINT, WITH CERTIFICATE OF CONFERRAL on counsel of record for all parties in this matter via electronic service concurrently with the submission hereof for e-filing via the court’s online filing system. /s/ Eric N. Kibel – signature on file ____________________________________ 3