HomeMy WebLinkAbout2020CV30363 - Stuward Cross And Katrina Richman V. City Of Fort Collins - 057 - Pls' Mot Extension Of Time Reply To MilDISTRICT COURT, LARIMER COUNTY, STATE OF
COLORADO
Court Address:
201 Laporte Ave.
Fort Collins, CO 80621
Plaintiffs:
STUWARD CROSS AND KATRINA RICHMAN
v.
Defendant:
THE CITY OF FORT COLLINS, STATE OF
COLORADO
Court Use Only
Attorneys for Plaintiffs:
Laura Browne, # 46673
Ashley Fridovich, # 47538
WILHITE, ROSE, MCCLURE &, SAWAYA P.C.
1600 Ogden Street
Denver, CO 80218
Phone Number: (303) 839-1650
FAX Number: (303) 832-7102
E-mail: lbrowne@sawayalaw.com
afridovich@sawayalaw.com
Case Number: 2020CV30363
Division: 3C
PLAINTIFFS’ UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE REPLIES AND RESPONSES TO MOTIONS IN LIMINIE
COME NOW, Plaintiffs Stuward Cross and Katrina Richman, by and through their attorneys of
record, Wilhite, Rose, McClure, and Sawaya, P.C., and hereby submits their Unopposed Motion for
Extension of Time to File their Replies and Responses to Motions in Limine, states the following:
C.R.C.P. 121 CONFERRAL
Counsel for Plaintiffs conferred with counsel for Defendant, who does not oppose this
Motion.
BACKGROUND
1. Plaintiffs filed their Complaint on May 29, 2020.
2. A five-day jury trial is set to begin November 15, 2021.
DATE FILED: October 26, 2021 2:59 PM
FILING ID: 3E37DCBED9076
CASE NUMBER: 2020CV30363
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3. The deadline for Plaintiffs to file their Replies and Responses to the Motions in Limine is October
25, 2021.
4. Plaintiffs request a one-week extension of time to file these motions.
5. The Defendant does not oppose this Motion.
6. No party will be prejudiced by the one-week extension of time to file the replies and responses
to the Motions in Limine.
7. The requested extension of time will not affect the parties’ ability to prepare for trial.
CONCLUSION
WHEREFORE, Plaintiff respectfully requests this Court GRANT Plaintiff’s Unopposed
Motion for Extension of Time to File Replies and Reponses to Motions in Limine through November
1, 2021.
DATED: October 26, 2021.
Respectfully submitted,
WILHITE, ROSE, MCCLURE & SAWAYA, P.C.
/s/ Ashley Fridovich
Original Signature on File in Attorney’s Office
Ashley Fridovich, Attorney for Plaintiff
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CERTIFICATE OF SERVICE
I hereby certify that on October 26, 2021 this PLAINTIFF’S UNOPPOSED MOTION
FOR EXTENSION OF TIME TO REPLIES AND RESPONSES TO MOTIONS IN
LIMINIE was filed and served via CCEF addressed to the following counsel of record:
Andrew W. Callahan, Esq.
Julie M. Yates, Esq.
WICK & TRAUTWEIN, LLC
P.O. Box 2166
Fort Collins, CO 80522
Attorney for Defendant
Adam Stephens, Esq.
John R. Duval, Esq.
FORT COLLINS CITY
ATTORNEY’S OFFICE
P.O. Box 580
Fort Collins, CO 80522
Attorney for Defendant
/s/ Kassandra Burival
Original Signature on File in Attorney’s Office
Kassandra Burival, Litigation Paralegal