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 - 056B - Joint Filing For The April 29 2022 HearingLarimer County District Court
201 La Porte Ave, Suite 100
Fort Collins. CO 80521
FOR COURT USE ONLY
SAVE THE POUDRE, and
NO PIPE DREAM CORPORATION,
Plaintiffs,
v.
NORTHERN COLORADO WATER CONSERVANCY
DISTRICT, and
NORTHERN INTEGRATED 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
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
Case No. 21CV30425
THE PARTIES’ JOINT FILING FOR THE APRIL 29, 2022 HEARING
The parties submit this Joint Filing governing the April 29, 2022 hearing.
A. Witnesses:
None of the parties intend to call witnesses.
DATE FILED: April 22, 2022 8:52 AM
FILING ID: 3B7163DF94CCD
CASE NUMBER: 2021CV30425
2
B. Joint Exhibits: The parties jointly stipulate to the admissibility of the following
exhibits for all purposes. Each Joint Exhibit listed below is being filed along with
this Joint Filing. An Exhibit List is attached to this filing.
1. June 10, 2020 Memorandum, City of Fort Collins, Land Conservation and
Stewardship Board. Exhibit 1.
2. City of Fort Collins, Land Use Code, Article 2. Exhibit 2
3. January 6, 2022 Stipulation between Northern Water and City of Fort
Collins. Exhibit 3.
4. Certified transcript of the Northern Water’s Board’s August 12, 2021
public hearing. Exhibit 4.
5. Documents provided to the Northern Board at its August 12, 2021 hearing.
Submitted as Exhibits 5 – 19 to comply with CJD 11-01
C. Additional briefing:
On April 22, 2022, Defendant Northern Water is filing supplemental brief on the
legal issues to be addressed at the April 29, 2022 hearing. Plaintiffs do not
oppose Northern Water’s supplemental briefing and Northern Water does not
oppose a response by Plaintiffs or Defendant City filed on or before April 27th.
Respectfully submitted: April 22, 2022.
TROUT RALEY
S/ Peggy E. Montaño
By: Peggy E. Montaño, #11075
Bennett W. Raley, #13429
William Davis Wert, #48722
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.
CERTIFICATE OF SERVICE
I certify that on April 22, 2022, a true and correct copy of the foregoing THE PARTIES’
JOINT FILING FOR THE APRIL 29, 2022 HEARING 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 Attorney’s 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/ Meichell Walsh
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