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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 - 041 - 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 UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO PLAINTIFF’S AMENDED COMPLAINT AND THE CITY OF FORT COLLINS’ CROSS-CLAIM 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 and the NISP Enterprise to file an answer or other response to Plaintiffs’ amended complaint and DATE FILED: November 18, 2021 5:45 PM FILING ID: 5442C1778C632 CASE NUMBER: 2021CV30425 1 the City of Fort Collins’ Cross-Claim. The current deadline as set out in the Court’s Order Granting Defendants Partial Motion to Dismiss (“Dismissal Order”) is December 1, 2021. Northern Water and the NISP Enterprise respectfully request until December 10, 2021 to respond. The current deadline of December 1, 2021 does not allow Counsel for Northern Water and the NISP Enterprise to consult with their client regarding the Court’s recent Dismissal Order and the remaining claims in this case because the next meeting of the Board of Directors for Northern Water is December 2, 2021. 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. Respectfully submitted: November 18, 2021. 2 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 November 18, 2021, a true and correct copy of the foregoing Defendants Northern Colorado Water Conservancy District and Northern Integrated Supply Project Water Activity Enterprise’s Unopposed Motion for Enlargement of Time to Respond to Plaintiffs’ Amended Complaint and the City of Fort Collins’ Cross-Claim 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 City of Fort Collins John R Duval City Attorneys Office 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