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HomeMy WebLinkAbout2021CV30426 - City Of Fort Collins V. Aaron Million, Jordan Fox-Million; Million Agricultural Investments, Ltd., Arlo Richardson Aka Arlo Lee Richardson; The Pleasant Valley And Lake Canal Ditch Company - 065 - Pl's 2D Mot Extension Deadlines1 District Court, Larimer County, Colorado 201 Laporte Avenue, Suite 100 Fort Collins, Colorado 80521 (970) 494-3500 Court Use Only Plaintiff: CITY OF FORT COLLINS, a Colorado home rule municipality, v. Defendants: AARON MILLION et al. Attorneys for Plaintiff Peter J. Dauster (#37139) Daniel M. St. John II (#46653) Johnson Muffly & Dauster, PC 323 South College Avenue, Suite 1 Fort Collins, Colorado 80524 Telephone: 970-482-4846; FAX: 970-482-3038 pdauster@nocolawgroup.com dstjohn@nocolawgroup.com Ingrid E. Decker (#28594) Senior Assistant City Attorney Fort Collins City Attorney’s Office 300 LaPorte Ave. Fort Collins, Colorado 80521 Telephone: 970-416-2553 Email: idecker@fcgov.com Case No. 21CV30426 Courtroom: 5B PLAINTIFF’S SECOND UNOPPOSED MOTION TO EXTEND C.R.C.P. 26(a)(2) EXPERT DISCLOSURE DEADLINES Plaintiff City of Fort Collins (“City”), through its attorneys, Johnson Muffly & Dauster, P.C. and Fort Collins City Attorney’s Office, hereby submits its Second Motion to Extend C.R.C.P. 26(a)(2) Expert Disclosure Deadlines, and as grounds states as follows: C.R.C.P. 121, § 1-15 CERTIFICATION Pursuant to C.R.C.P. 121, § 1-15, the undersigned states that he has conferred with Defendant Aaron Million, who spoke for himself and Defendant Jordan Fox-Million, regarding the relief requested herein, and they do not oppose this Motion. 2 1. Pursuant to the Order Granting Plaintiff’s Unopposed Motion to Extend C.R.C.P. 26(a)(2) Expert Disclosure Deadlines issued on September 6, 2022 the current expert witness disclosure deadlines are as follows: i. Plaintiff/claimant: October 3, 2022 ii. Defendant/opposing party: October 31, 2022 iii. Rebuttal expert reports: November 21, 2022 2. The parties are exploring settlement and require additional time to finalize the terms of the settlement agreements. Such resolution would be better facilitated by an extension of the expert witness deadlines. 3. The parties request a month extension of the C.R.C.P. 26(a)(2) expert witness disclosure deadlines as follows: i. Plaintiff/claimant: November 4, 2022 ii. Defendant/opposing party: November 4, 2022 iii. Rebuttal expert reports: December 2, 2022 4. No parties will be prejudiced by this unopposed request. This request will not jeopardize the three-day court trial set to begin on February 6, 2022. DATED this 30th day of September 2022. JOHNSON MUFFLY & DAUSTER, PC /s/Daniel M. St. John II* Peter J. Dauster (#37139) Daniel M. St. John II (#46653) Attorneys for City of Fort Collins 3 FORT COLLINS CITY ATTORNEY’S OFFICE _/s/Ingrid E. Decker * Ingrid E. Decker (#28594) Senior Assistant City Attorney Attorneys for City of Fort Collins CERTIFICATE OF SERVICE THIS IS TO CERTIFY that on this 30th day of September 2022, a true and correct copy of the above and foregoing PLAINTIFF’S SECOND UNOPPOSED MOTION TO EXTEND C.R.C.P. 26(a)(2) EXPERT DISCLOSURE DEADLINES was served as follows: Ingrid Decker City Attorney’s Office 300 LaPorte Avenue Fort Collins, Colorado 80522 Co-Counsel for Plaintiff Via CCE Aaron Million 1436 West Oak Fort Collins, Colorado 80521 Via U.S. Mail and email to million_1@hotmail.com Jeffrey J. Kahn Lyons Gaddis, P.C. 515 Kimbark Street, 2nd Floor PO Box 978 Longmont, Colorado 80502 Counsel for Defendant Pleasant Valley and Lake Canal Company Via CCE Jordan Fox-Million 3172 Stargazer Court Fort Collins, Colorado 80521 Via U.S. Mail and email to jordanfoxmillion@gmail.com /s/ Mariana Walters* For Johnson Muffly & Dauster, PC *ELECTRONICALLY FILED: Original signatures maintained pursuant to C.R.C.P. 121 Sec. 1-26 at the offices of Johnson Muffly & Dauster PC and available for inspection by the Court and other parties upon request.