HomeMy WebLinkAbout2023CV30130 - City Of Fort Collins V. Directional Plus, Et Al. - 021 - City's Motion To Modify CmoDISTRICT COURT, LARIMER COUNTY, COLORADO
201 LaPorte Ave., Ste. 100
Fort Collins, CO 80521
(970) 494-3500
COURT USE ONLY
Plaintiff: CITY OF FORT COLLINS
v.
Defendants: DIRECTIONAL PLUS, LLC, and
MASTEC NORTH AMERICA, INC.
Andrew W. Callahan, #52421 – acallahan@wicklaw.com
WICK & TRAUTWEIN, LLC
323 South College Avenue, Suite 3
Fort Collins, CO 80524
Phone & Fax Number: (970) 482-4011
Case No.: 2023 CV 30130
Division: 3B
UNOPPOSED MOTION TO MODIFY THE PRETRIAL DEADLINES IN THE CASE
MANAGEMENT ORDER
Plaintiff City of Fort Collins, by and through undersigned counsel, Wick & Trautwein,
LLC, respectfully submits its Unopposed Motion to Modify the Pretrial Deadlines currently set in
the Case Management Order. As grounds for same, Plaintiff states as follows:
Rule 121 Certification: Undersigned counsel has conferred with counsel for Directional
Plus and Mastec North American regarding the relief requested herein. Counsel consent to the
requested extension of time.
1. The parties have experienced a delay in scheduling depositions and respectfully
request that the deadlines outlined in the Case Management Order be extended by 30 days to allow
for the scheduling of requested depositions.
2. The Case Management Order entered by the court on May 17, 2023 contains the
following deadlines in Paragraph 13 pertaining to expert disclosures:
DATE FILED: August 29, 2023 2:55 PM
FILING ID: FFEF52A5FB394
CASE NUMBER: 2023CV30130
Plaintiff: September 8, 2023
Defendants: October 13, 2023
Rebuttal Reports: November 3, 2023
3. The Case Management Order also contains the following pretrial deadlines:
ADR Deadline: October 31, 2023
Discovery Cut Off: December 4, 2023
Deadline to file Notice to Set Trial: December 6, 2023
4. The parties request these deadlines be extended by 30 days and that the Case
Management Order be modified to reflect the following new deadlines:
Plaintiff’s Expert Disclosures: October 9, 2023
Defendant’s Expert Disclosures: November 13, 2023
Rebuttal Expert Disclosures: December 4, 2023
ADR Deadline: December 1, 2023
Discovery Cut Off: January 3, 2024
Deadline to file Notice to Set Trial: January 5, 2024
WHEREFORE, Plaintiff respectfully requests the foregoing modifications to the Case
Management Order to reflect the new deadlines stated herein.
Respectfully submitted this 29th day of August, 2023.
WICK & TRAUTWEIN, LLC
By: s/ Andrew W. Callahan
Andrew W. Callahan, #52421
Attorney for Plaintiff
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing
UNOPPOSED MOTION TO MODIFY THE PRETRIAL DEADLINES IN THE CASE
MANAGEMENT ORDER was filed with the court via CES this 29th day of August, 2023, and
served on all counsel of record.
s/ Jody L. Minch
Paralegal