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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