HomeMy WebLinkAbout2020CV30363 - Stuward Cross And Katrina Richman V. City Of Fort Collins - 029 - Plaintiff's Unopposed Motion For Extension Of Time To File Pre-Trial MotionsDISTRICT COURT, LARIMER COUNTY,
STATE OF COLORADO
Court Address:
201 Laporte Ave.
Fort Collins, CO 80621
Plaintiffs:
STUWARD CROSS AND KATRINA RICHMAN
v.
Defendant:
THE CITY OF FORT COLLINS, STATE OF
COLORADO
Court Use Only
Attorneys for Plaintiffs:
Laura Browne, # 46673
WILHITE, ROSE, MCCLURE & SAWAYA, P.C.
1600 Ogden Street
Denver, CO 80218
Phone Number: (303) 839-1650
FAX Number: (303) 832-7102
E-mail: lbrowne@sawayalaw.com
Case Number: 2020CV30363
Division: 5A
PLAINTIFFS’ UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE PRETRIAL MOTIONS
COME NOW, Plaintiffs by and through their attorneys of record Wilhite, Rose, McClure,
and Sawaya, hereby submit their Unopposed Motion for Extension of Time to file Pretrial Motions, state
the following:
C.R.C.P. 121 CONFERRAL
Counsel for Plaintiffs conferred with counsel for the Defendant. This Motion is unopposed.
BACKGROUND
1. Plaintiffs filed their Complaint on May 29, 2020.
2. A five-day trial in this matter is scheduled to begin November 15, 2021.
3. The deadline for the parties to file pretrial motions is October 4, 2021.
DATE FILED: October 1, 2021 1:03 PM
FILING ID: CFE6E0607E543
CASE NUMBER: 2020CV30363
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4. Plaintiff requests a one-week extension of time to file pretrial motions.
5. Counsel for Defendant does not oppose this Motion.
6. No party will be prejudiced by the one-week extension of time to file pretrial motions.
7. The requested extension of time will not affect the parties ability to prepare for trial and no parties
are requesting to continue the trial date.
CONCLUSION
WHEREFORE, Plaintiffs respectfully requests this Court GRANT Plaintiffs’ Unopposed
Motion for Extension of Time to File Pretrial Motions through October 11, 2021.
DATED: October 1, 2021.
Respectfully submitted,
WILHITE, ROSE, MCCLURE & SAWAYA, P.C.
/s/ Laura Browne
Original Signature on File in Attorney’s Office
Laura Browne, Attorney for Plaintiff
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CERTIFICATE OF SERVICE
I hereby certify that on October 1, 2021 this PLAINTIFFS’ UNOPPOSED MOTION
FOR EXTENSION OF TIME TO FILE PRETRIAL MOTIONS was filed and served via
CCEF addressed to the following counsel of record:
Andrew W. Callahan, Esq.
WICK & TRAUTWEIN, LLC
P.O. Box 2166
Fort Collins, CO 80522
Attorney for Defendant
Adam Stephens, Esq.
FORT COLLINS CITY
ATTORNEY’S OFFICE
P.O. Box 580
Fort Collins, CO 80522
Attorney for Defendant
/s/ Kassandra Burival
Original Signature on File in Attorney’s Office
Kassandra Burival, Litigation Paralegal