HomeMy WebLinkAbout2020CV30363 - Stuward Cross And Katrina Richman V. City Of Fort Collins - 013 - Entry Of Appearance And Motion For Enlargement Of TimeDISTRICT COURT, LARIMER COUNTY, COLORADO
Larimer County Justice Center
201 Laporte Avenue, Suite 100
Fort Collins, CO 80521-2761
(970) 498-6100
Plaintiffs: STUWARD CROSS AND KATRINA
RICHMAN
v.
Defendant: THE CITY OF FORT COLLINS, State of
Colorado
COURT USE ONLY
Andrew W. Callahan, #52421
WICK & TRAUTWEIN, LLC
P.O. Box 2166
Fort Collins, CO 80522
Phone: (970) 482-4011
Email: acallahan@wicklaw.com
Case Number: 2020 CV 30363
Courtroom: 5A
ENTRY OF APPEARANCE AND UNOPPOSED MOTION FOR ENLARGEMENT
OF TIME TO FILE RESPONSIVE PLEADING
COMES NOW, undersigned counsel, Andrew W. Callahan of the law firm of Wick &
Trautwein, LLC, and enters his appearance as counsel for Defendant.
Defendant, through counsel, respectfully submits the following unopposed motion for
enlargement of time to file its responsive pleading to the Plaintiffs’ Complaint. In support
hereof, Defendant states as follows:
1. RULE 121 CERTIFICATION: Undersigned counsel for the Defendant hereby advises
the Court that he has conferred with Plaintiffs’ counsel about the enlargement of time requested
in this motion. Counsel for Plaintiffs consents to the relief requested herein.
2. Defendant signed a waiver and acceptance of service on August 6, 2020, which would
make their responsive pleading due on August 27, 2020. Defendant seeks an enlargement of
time up to and including September 10, 2020 to file a responsive pleading in this case.
3. This motion is made in good faith and in cooperation with other parties in this case. No
prejudice should be incurred to any party, as reflected by the consent and agreements described
above.
DATE FILED: August 26, 2020 3:48 PM
FILING ID: FBA4699120956
CASE NUMBER: 2020CV30363
2
Respectfully submitted this 26th day of August, 2020.
WICK & TRAUTWEIN, LLC
By: s/Andrew W. Callahan
Andrew W. Callahan, #52421
Attorneys for Defendant
CERTIFICATE OF ELECTRONIC FILING
The undersigned hereby certifies that a true and correct copy of the foregoing ENTRY
OF APPEARANCE AND UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO
FILE RESPONSIVE PLEADING was filed via the Colorado Courts E-Filing System and served
this 26th day of August, 2020, on the following:
W. Clayton Harris
The Sawaya Law Firm
1600 Ogden Street
Denver, CO 80218
s/ Jody L. Minch
[The original certificate of electronic filing signed by Jody L. Minch is on file at Wick &
Trautwein, LLC)