HomeMy WebLinkAbout2020CV30833 - City Of Fort Collins V. Planning Action To Transform Hughes Stadium Sustainably Corp, Et. Al - 009 - Waiver Of Service Of Summons And ComplaintDISTRICT COURT, COUNTY OF LARIMER,
COLORADO
Larimer County Justice Center
201 Laporte Avenue, Suite 100
Fort Collins, Colorado 80521-2762
(970) 498-6100
______________________________________________
Plaintiff: THE CITY OF FORT COLLINS, COLORADO,
a Colorado home rule city and municipal corporation,
v.
Defendants: PLANNING ACTION TO TRANSFORM
HUGHES STADIUM SUSTAINABLY CORP, a
Colorado nonprofit corporation; and ELENA M. LOPEZ,
MELISSA ROSAS, AND PAUL PATTERSON, each in
their official capacity as a petition representative of the
persons signing the petition for a citizen-initiated ordinance
relating to the City of Fort Collins rezoning and acquiring
certain real property
______________________________________________
Carrie M. Daggett #23316 - City Attorney
John R. Duval #10185 - Deputy City Attorney
Fort Collins City Attorney’s Office
300 Laporte Avenue
P.O. Box 500
Fort Collins, Colorado 80522
970-221-6520
cdaggett@fcgov.com , jduval@fcgov.com
Andrew D. Ringel #24762
Hall & Evans, L.L.C.
1001 17th Street, Suite 300
Denver, CO 80202
303-628-3300
Fax: 303-628-3368
ringela@hallevans.com
Attorneys for Plaintiff
▲COURT USE ONLY ▲
_________________________
Case Number: 2020CV30833
Division: ___
WAIVER OF SERVICE OF SUMMONS AND COMPLAINT
DATE FILED: December 8, 2020 9:49 AM
FILING ID: 798AE2DF1A278
CASE NUMBER: 2020CV30833
2
I, Michael Foote, Esq., on behalf of Defendants Planning Action to Transform Hughes
Stadium Sustainably Corp, Elena M. Lopez, Melissa Rosas, and Paul Patterson hereby
acknowledge receipt of the following items via electronic mail on December 7, 2020:
1. Complaint for Review Pursuant to C.R.C.P. 57 and the Uniform Declaratory
Judgment Law with Exhibits A-L;
2. Civil Cover Sheet;
3. District Court Civil Summonses for each Defendant;
4. Motion for Expedited Consideration and proposed Order.
I hereby agree to waive personal service of the Summons and Complaint pursuant to
C.R.C.P. 4(e) and instead waive service pursuant to C.R.C.P. 4(i). I understand no waiver of any
objection other than an objection to service of process occurs based on this waiver. I also
understand the Defendants are required to respond to the Complaint for Review Pursuant to
C.R.C.P. 57 within 21 days of the date this Waiver is executed and is required to respond to the
Motion for Expedited Consideration within 21 days of the date this Waiver is executed, although
I also acknowledge and understand the District Court may rule on the Motion prior to this time.
Dated this 8th day of December, 2020.
Michael Foote, Esq.