HomeMy WebLinkAbout2023CV228 - Lynne V. Yonce - 10 - City Identification Of Custodian And Unopp Mot Dismiss Other Defendants1
DISTRICT COURT, LARIMER COUNTY, COLORADO
201 LaPorte Ave., Ste. 100
Fort Collins, CO 80521
(970) 494-3500
COURT USE ONLY
Plaintiff: STACY LYNNE, Investigative Journalist
v.
Defendants: DAWN DOWNS, Assistance City Attorney,
City of Fort Collins; JEREMY YONCE, Lieutenant,
Professional Standards Unit, Fort Collins Police Services;
LISA ROBLES, Senior Manager Information Systems, Fort
Collins Police Services
Andrew W. Callahan, #52421 – acallahan@wicklaw.com
Cassie L. Williams, #58279 – cwilliams@wicklaw.com
WICK & TRAUTWEIN, LLC
323 South College Avenue, Suite 3
Fort Collins, CO 80522
Phone & Fax Number: (970) 482-4011
Case No.: 2023 CV 228
Division: 3B
IDENTIFICATION OF CUSTODIAN OF RECORDS AND UNOPPOSED MOTION TO
DISMISS REMAINING DEFENDANTS
COME NOW Defendants Jeremy Yonce, Dawn Downs and Lisa Robles, by and through
their attorneys, Wick & Trautwein, LLC, and for their Identification of Custodian of Records and
Unopposed Motion to Dismiss Remaining Defendants, state as follows:
Pursuant to the Court’s Order to Show Cause dated November 21, 2023, Defendants
identify and stipulate that Jeremy Yonce is the custodian of records for Internal Affairs files for
Fort Collins Police Services and the proper Defendant is this case.
Defendants request that Defendants Dawn Downs and Lisa Robles be dismissed from the
Petition for an Order to Show Cause, as they are not the custodian for the records at issue.
Undersigned counsel has conferred with Plaintiff Stacy Lynne, and she is unopposed to dismissing
Down Downs and Lisa Robles.
DATE FILED: November 30, 2023 8:15 AM
FILING ID: 9A605515586AD
CASE NUMBER: 2023CV228
2
Defendants further request that the case caption in this case be reformed to read: “Stacy
Lyne, Investigative Journalist, Plaintiff v. Jeremy Yonce, in his official capacity as Internal Affairs
records custodian for Fort Collins Police Services”.
WHEREFORE Defendants request that Dawn Downs and Lisa Robles be dismissed from
the lawsuit without prejudice and that Defendant Jeremy Yonce be named in his official capacity
as Internal Affairs records custodian for Fort Collins Police Services, and for such other relief as
is just and reasonable.
Respectfully submitted this 30th day of November, 2023.
WICK & TRAUTWEIN, LLC
By: s/ Andrew W. Callahan
Andrew W. Callahan, #52421
Cassie L. Williams, #58279
Attorney for Defendants
CERTIFICATE OF ELECTRONIC FILING
The undersigned hereby certifies that a true and correct copy of the foregoing IDENTIFICATION
OF CUSTODIAN OF RECORDS AND UNOPPOSED MOTION TO DISMISS
REMAINING DEFENDANTS was filed with the court via Colorado Courts E-filing System
(CCES) this 30th day of November, 2023, and served on the following:
Stacy Lynne
305 West Magnolia Street #282
Fort Collins, CO 80521
Via email to stacy_lynne@comcast.net
Pro se Plaintiff
/s/ Jody L. Minch