HomeMy WebLinkAbout2021CA833 - City Of Fort Collins V. Board Of County Commissioners Of Larimer County, Et Al - 020 - Motion To Change Date Of Oral ArgumentColorado Court of Appeals
2 East 14th Avenue
Denver, CO 80203
County of Larimer
Case No. 2020CV30580, Division 4B
The Honorable Daniel McDonald
________________________________________
Plaintiff-Appellant:
THE CITY OF FORT COLLINS, COLORADO, a
municipal corporation,
v.
Defendants--Appellees:
BOARD OF COUNTY COMMISSIONERS OF
LARIMER COUNTY, COLORADO;
STREETMEDIAGROUP, LLC
Andrew D. Ringel, Esq. (#24762)
Hall & Evans, L.L.C.
1001 - 17th Street, Ste. 300
Denver, CO 80202
303-628-3300
Fax: 303-628-3368
ringela@hallevans.com
John R. Duval, Esq. (#10185)
Deputy City Attorney
Claire Havelda, Esq. (#36831)
Assistant City Attorney
City Attorney’s Office
300 Laporte Avenue
P.O. Box 500
Fort Collins, Colorado 80522
▲COURT USE ONLY▲
______________________
Case Number:
2021CA833
______________________
DATE FILED: May 24, 2022 4:55 PM
FILING ID: 348ECC615C3F5
CASE NUMBER: 2021CA833
2
970-221-6652
Fax: 970-221-6327
jduval@fcgov.com
chavelda@fcgov.com
Attorneys for Plaintiff-Appellant
UNOPPOSED MOTION TO CHANGE DATE OF ORAL ARGUMENT
Plaintiff-Appellant the City of Fort Collins, Colorado, by and through its
counsel, Andrew D. Ringel, Esq. of Hall & Evans, L.L.C., and John R. Duval, Esq.,
Deputy City Attorney, and Claire Havelda, Esq., Assistant City Attorney, of the Fort
Collins City Attorney’s Office, hereby respectfully submits this Unopposed Motion
to Change Date for Oral Argument, as follows:
1. On May 17, 2022, this Court issued its Notice of Oral Argument setting
oral argument for July 12, 2022, at 1:30 p.m. The undersigned counsel will be
arguing for Plaintiff-Appellant. The undersigned counsel is arguing because he
prepared and filed all of filings before the District Court and this Court. The
undersigned counsel has a planned scheduled vacation that conflicts with the July
12, 2022, oral argument date and will be out of town and not available to participate
in oral argument. As a result, the Plaintiff-Appellant respectfully requests this Court
reschedule the trial date.
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2. Prior to filing this Motion, the undersigned counsel conferred with
counsel for the Defendants-Appellees, Frank Haug, Esq. and Todd Messenger, Esq.
Mr. Haug and Mr. Messenger indicated the Defendants-Appellees do not object to
this Motion.
3. In addition, the undersigned counsel conferred with counsel for the
other parties about their availability for a rescheduled oral argument in this matter.
The following dates in July and August do not work for a rescheduled oral argument
based on the calendars of counsel: July 5, 6, 7, 8, 11, 12, 13, 14, 15, 18, 19, 20, 21,
22, 23, 24, 25, 26, 27, 28, and 29. and August 12, 15, 16, 17, 18, 19, 22, 23, 24, 25,
26, 29, 30 and 31. All other dates in July and August are workable for a rescheduled
oral argument before this Court. If none of the remaining dates work for the Court
the undersigned counsel is happy to clear dates in September for all counsel and
inform this Court in any appropriate fashion as directed by the Court.
WHEREFORE, Plaintiff-Appellant The City of Fort Collins, Colorado
respectfully requests this Court reschedule the oral argument set for July 12, 2022,
at 1:30 p.m. to a different available date as outlined in paragraph 3 above, and for all
other an further relief as this Court deems just and appropriate.
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Dated this 24th day of May, 2022.
Respectfully submitted,
/s/ Andrew D. Ringel
Andrew D. Ringel, #24762
of HALL & EVANS, L.L.C.
ATTORNEYS FOR PLAINTIFF-
APPELLANT THE CITY OF FORT
COLLINS
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CERTIFICATE OF E-FILING AND SERVICE
I hereby certify that on the 24th day of May, 2021, I E-Filed the foregoing
with the Clerk of the Court via ICCES and served a copy via electronic service on
the following individual via the following email addresses:
Jeannine S. Haag, Esq.
jeanninehaag@co.larimer.org
William G. Ressue, Esq.
wressue@co. larimer.org
Frank N. Haug, Esq.
haughfn@co.larimer.org
Todd G. Messenger, Esq.
tmessenger@fwlaw.com
Amanda C. Jokerst, Esq.
ajokerst@fwlaw.com
John R. Duval, Esq.
jduval@fcgov.com
Claire Havelda, Esq.
chavelda@fcgov.com
/s/ Nicole Marion