Loading...
HomeMy WebLinkAbout2021CV30425 - Save The Poudre And No Pipe Dream Coporation V. Northern Colorado Water Conservancy District, Northern Integrated Supply Project Water Activity Enterprise, The City Of Fort Collins - 021 - Motion For Enlargement Of TimeLarimer County District Court 201 La Porte Ave, Suite 100 Fort Collins, CO 80521 COURT USE ONLY SAVE THE POUDRE, and NO PIPE DREAM CORPORATION Plaintiffs v. NORTHERN COLORADO WATER CONSERVANCY DISTRICT, NORTHERN INTERGRATED SUPPLY PROJECT WATER ACTIVITY ENTERPRISE, THE CITY OF FORT COLLINS, a Colorado home rule city and municipal corporation, Defendants. Attorneys for Northern Colorado Water Conservancy District and Northern Integrated Supply Project Water Activity Enterprise: Bennett W. Raley, #13429 Peggy E. Montaño, #11075 William Davis Wert, #48722 Mirko L. Kruse, #52488 TROUT RALEY 1120 Lincoln Street, Suite 1600 Denver, CO 80203 Telephone: (303) 861-1963 FAX Number: (303) 832-4465 email: braley@troutlaw.com, pmontano@troutlaw.com, dwert@troutlaw.com, mkruse@troutlaw.com Case No. 21CV30425 DEFENDANTS NORTHERN COLORADO WATER CONSERVANCY DISTRICT AND NORTHERN INTEGRATED SUPPLY PROJECT WATER ACTIVITY ENTERPRISE’S MOTION FOR ENLARGMENT OF TIME TO RESPOND TO PLAINTIFFS’ AMENDED COMPLAINT AND MOTION TO PREPARE AND CERTIFY THE ADMINISTRATIVE RECORD Defendants, the Northern Colorado Water Conservancy District (“Northern Water”) and Northern Integrated Supply Project Water Activity Enterprise (“NISP Enterprise”), by and through its undersigned attorneys, hereby request that the Court extend the deadline for Northern Water DATE FILED: September 16, 2021 1:06 PM FILING ID: 28DC93AA53B3D CASE NUMBER: 2021CV30425 1 and the NISP Enterprise to file an answer or other response to Plaintiffs’ amended complaint. The current deadline as set out in the Court’s Order Amending Scheduling Order is September 21, 2021. Northern Water and the NISP Enterprise respectfully request until September 28, 2021 to respond. In addition, Plaintiffs filed a motion for Northern Water to prepare an administrative record pursuant to C.R.C.P. 106(a)(4)(III). Northern Water also requests until September 28, 2021 to respond to this motion. Counsel for Northern Water and the NISP Enterprise have been and will be attending to several other pressing matters until the current filing deadlines. Therefore, Northern Water and the NISP Enterprise request this brief extension. Pursuant to C.R.C.P. 121 § 1-15(8), counsel for Northern Water and the NISP Enterprise certify that they conferred with the other parties regarding the relief requested in this Motion. The City of Fort Collins and Plaintiffs do not oppose this Motion. 2 Respectfully submitted: September 16, 2021. TROUT RALEY /s/ Mirko Kruse Peggy E. Montaño, #11075 Bennett W. Raley, #13429 William Davis Wert, #48722 Mirko L. Kruse, #52488 1120 Lincoln Street, Suite 1600 Denver, CO 80203 Telephone: (303) 861-1963 Facsimile: (303) 832-4465 braley@troutlaw.com pmontano@troutlaw.com dwert@troutlaw.com mkruse@troutlaw.com Attorneys for Defendants, Northern Colorado Water Conservancy District and Northern Integrated Supply Project Water Activity Enterprise Pursuant to C.R.C.P. 121, a printed or printable copy of the document bearing the original, electronic, or scanned signatures is on file in the offices of counsel. 3 CERTIFICATE OF SERVICE I certify that on September 16, 2021, a true and correct copy of the foregoing Defendants Northern Colorado Water Conservancy District And Northern Integrated Supply Project Water Activity Enterprise’s Motion For Enlargment Of Time To Respond To Plaintiffs’ Amended Complaint And Motion To Prepare And Certify The Administrative Record was served via the Colorado Courts E-Filing System, on the following: Name Attorney Organization City of Fort Collins Marni L Nathan Kloster Nathan Dumm and Mayer PC City of Fort Collins Nicholas Poppe Nathan Dumm and Mayer PC No Pipe Dream Corporation John Mclain Barth John M Barth Attorney at Law Save the Poudre John Mclain Barth John M Barth Attorney at Law S/ Britta Petersen E-filed pursuant to C.R.C.P. 121 §1-26 via the Colorado Courts E-Filing System. A printed or printable copy of this document bearing the original, electronic, or scanned signatures is on file at the office of Trout Raley