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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 - 046 - Motion To Approve StipulationLarimer 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, and NORTHERN INTERGRATED SUPPLY PROJECT WATER ACTIVITY ENTERPRISE, Defendants, and THE CITY OF FORT COLLINS, a Colorado home rule city and municipal corporation, Defendant–Cross-Claimant. 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 MOTION FOR APPROVAL OF STIPULATION BETWEEN NORTHERN COLORADO WATER CONSERVANCY DISTRICT, NORTHERN INTEGRATED SUPPLY PROJECT WATER ACTIVITY ENTERPRISE, AND CITY OF FORT COLLINS DATE FILED: January 6, 2022 7:38 PM FILING ID: 3D93A2567287C CASE NUMBER: 2021CV30425 Defendants, the Northern Colorado Water Conservancy District (“Northern Water”) and the Northern Integrated Supply Project Water Activity Enterprise’s (“NISP Enterprise”), hereby move this Court for an Order approving the Stipulation between Northern Water, the NISP Enterprise, and the City of Fort Collins (collectively, the “Parties”). As grounds therefor, Northern Water and the NISP Enterprise state as follows: The Parties entered into the Stipulation, a copy of which is attached hereto. The Stipulation resolves all issues between the Parties, including the City of Fort Collins’ Cross- Claim filed September 28, 2021, with respect to the above-captioned matter. The Parties wish to have the Court approve the Stipulation so that it is enforceable as an Order of the Court. Plaintiffs oppose this Motion. A proposed Order is attached hereto. Respectfully submitted: January 6, 2022. TROUT RALEY __/s/ Peggy E. Montaño________________ By: Peggy E. Montaño, #11075 Bennett W. Raley, #13429 William Davis Wert, #48722 Mirko L. Kruse, #52488 Attorneys for Defendants, Northern Colorado Water Conservancy District and Northern Integrated Supply Project Water Activity Enterprise CERTIFICATE OF SERVICE I certify that on January 6, 2022, a true and correct copy of the foregoing Motion for Approval of Stipulation 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