HomeMy WebLinkAbout2022-cv-1983 - Townley v. Fort Collins, et al - 047 - Joint Status Report
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 1:22-cv-01983-SKC
MICHAEL PIPER TOWNLEY, ANNA KRUGER, and JOSHUA DeLEON;
Plaintiffs,
v.
BRIAN MALLORY, in his individual capacity;
ETHAN VANSICKLE, in his individual capacity;
DANIEL NETZEL, in his individual capacity;
JARED ROBERTSON, in his individual capacity;
JOE SCHILZ, in his individual capacity;
JASON HAFERMAN, in his individual capacity;
CHRISTOPHER YOUNG, in his individual capacity.
Defendants.
JOINT STATUS REPORT
The Parties, by and through their undersigned counsel, respectfully submit this Joint
Status Report pursuant to ECF No. 37.
1. Summary of Parties’ Discovery
a. Plaintiffs
Plaintiffs have served the City of Fort Collins with a subpoena requesting certain
documents related to Plaintiffs’ claims. As of the date of this filing, Plaintiffs have not received
any documents and the City objected to every request on April 12, 2023. Plaintiffs will be filing
a Motion to Compel based on Fort Collins’ responses shortly.
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b. Defendants
The Defendants recently served written discovery on the Plaintiffs, and asked Counsel for
deposition availability. It is expected Plaintiffs’ depositions will begin in late May to early June,
after responses to discovery are received.
2. Pending Discovery Disputes
As of the filing of this Joint Status Report, no Motions to compel have been filed.
However, as indicated above, Plaintiffs intend to file a Motion to Compel based on a subpoena
served on the City of Fort Collins.
Defendants: Mark S. Ratner, Counsel for the Defendants except Mr. Haferman, will
represent the City of Fort Collins if Plaintiffs’ file a Motion to Compel. The City of Fort Collins
is not a party to this matter.
3. Pending Motions
Pending before the Court are Motions to Dismiss Plaintiffs’ Amended Complaint filed on
behalf of Defendants VanSickle, Schilz, Haferman, and Young (ECF 22), and separately on behalf
of Defendant Netzel (ECF 41). The Motions are fully briefed.
4. Likelihood of Settlement
As of the filing of this Joint Status Report, the parties have yet to have any discussions on
settlement. The parties are only in the early stages of discovery and will likely need to engage in
further discovery before fruitful settlement discussions can occur.
Respectfully submitted this 14th day of April 2023.
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/s/ E. Milo Schwab
E. Milo Schwab
Ascend Counsel, LLC
2401 S. Downing St.
(303) 888-4407
milo@ascendcounsel.com
COUNSEL FOR PLAINTIFFS
/s/ Mark S. Ratner
Mark S. Ratner, Esq.
Andrew D. Ringel, Esq.
Katherine N. Hoffman, Esq.
1001 Seventeenth Street, Suite 300
Denver, CO 80202
(303) 628-3300
ratnerm@hallevans.com
ringel@hallevans.com
hoffmank@hallevans.com
COUNSEL FOR DEFENDANTS
MALLORY, VANSICKLE, NETZEL
ROBERTSON, SCHILZ, and YOUNG
/s/ Jonathan M. Abramson
Jonathan M. Abramson
Yulia Nikolaevskaya
Kissinger & Fellman, P.C.
3773 Cherry Creek North Drive
Ptarmigan Place, Suite 900
Denver, CO 80209
(303) 320-6100
jonathan@kandf.com
julie@kandf.com
COUNSEL FOR DEFENDANT
HAFERMAN
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