HomeMy WebLinkAbout2020CV30580 - City Of Fort Collins V. Board Of County Commissioners Of Larimer County, Colorado And Streetmediagroup, Llc - 026 - Motion For Extension To Answer Street Media Group Cross Claim
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Larimer County District Court
Larimer County, Colorado
201 La Porte Ave, Suite 100
Fort Collins, CO 80521
(970) 494-3500
Court Use Only
Plaintiff:
THE CITY OF FORT COLLINS, COLORADO, a municipal
corporation,
v.
Defendants:
BOARD OF COUNTY COMMISSIONERS OF LARIMER
COUNTY, COLORADO; STREETMEDIAGROUP, LLC
Frank N. Haug, Reg. No. 41427
Jeannine Haag, Reg. No. 11995
Larimer County Attorney’s Office
Post Office Box 1606
Fort Collins, Colorado 80522
Telephone (970) 498-7450
fhaug@larimer.org
jeanninehaag@larimer.org
Case No. 2020 CV 30580
Courtroom: 4B
DEFENDANT BOARD OF COUNTY COMMISSIONERS’ UNOPPOSED
MOTION TO EXTEND DEADLINE TO FILE RESPONSIVE PLEADING TO
DEFENDANT STREET MEDIA’S CROSSCLAIM
Defendant Board of County Commissioners of Larimer County (“County”), by and through
the Larimer County Attorney’s Office, moves this Court for an extension of time to file a response
to Defendant Street Media’s crossclaim, to and including January 15, 2021 and in support states as
follows:
1. Defendant County’s responsive pleading is due January 4, 2021, because the
crossclaim was filed on Saturday, December 12, 2020.
DATE FILED: December 28, 2020 3:38 PM
FILING ID: 5F5E9B656AE4D
CASE NUMBER: 2020CV30580
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2. Counsel for Defendant conferred with Plaintiff’s and Defendant Street Media’s
counsel requesting an extension until Friday January 15, 2021 to file a response to the crossclaim.
Plaintiff’s counsel does not object. Counsel for Defendant Street Media also does not object to the
extension but notes that they are not waiving their right to assert damages during the extended
period.
3. The extension is needed due to the need to research the matters involved, as well as
the fact that the current due date falls right after the holidays and previously scheduled county
closures on December 24, 25, 31, 2020 and January 1, 2021 and previously scheduled vacation
days.
4. No extensions have been previously requested with respect to the responsive
pleading.
WHEREFORE, the Defendants request this court for an order granting an extension to and
including January 15, 2021 to file a responsive pleading to Defendant Street Media’s crossclaim.
Dated: December 28, 2020
LARIMER COUNTY ATTORNEY’S OFFICE.
By: s/Frank N. Haug
Frank N. Haug, Reg. No. 41427
Jeannine Haag, Reg. No. 11995
Larimer County Attorney’s Office
Post Office Box 1606
Fort Collins, Colorado 80522
Telephone (970) 498-7450
fhaug@larimer.org
jeanninehaag@larimer.org
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CERTIFICATE OF SERVICE
The undersigned certifies that a true and correct copy of the foregoing DEFENDANT
BOARD OF COUNTY COMMISSIONERS’ UNOPPOSED MOTION TO EXTEND DEADLINE
TO FILE RESPONSIVE PLEADING TO DEFENDANT STREET MEDIA’S CROSSCLAIM was
served on the parties via the Colorado Court E-Filing System this 28th day of December, 2020,
addressed to:
Andrew D. Ringel
Hall & Evans, L.L.C.
1001 17th Street, Suite 300
Denver, CO 80202
ringela@hallevans.com
John R. Duval
Claire Havelda
City Attorney’s Office
300 Laporte Avenue
P.O. Box 500
Fort Collins, Colorado 80522
jduval@fcgov.com
chavelda@fcgov.com
Todd Messenger
Andrew J. Helm
Fairfield and Woods, P.C.
1801 California Street, Suite 2600
Denver, Colorado 80202-2645
tmessenger@fwlaw.com
ahelm@fwlaw.com
s/Jennifer D. Infeld