HomeMy WebLinkAbout2023-cv-1339 - Groves v. City of Fort Collins, et al - 061 - Plaintiff's Unopp Mot Amend Scheduling order to Extend Discovery Deadlines 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 23-CV-01339-RM-STV
DERRICK GROVES,
Plaintiff,
v.
CITY OF FORT COLLINS, and
JASON HAFERMAN,
Defendants.
PLAINTIFF’S UNOPPOSED MOTION TO AMEND SCHEDULING ORDER [ECF 33]
TO EXTEND DISCOVERY DEADLINES
Plaintiff Derrick Groves, by and through his attorney, respectfully submits this
Unopposed Motion to Amend Scheduling Order to Extend Discovery Deadlines, and in
support of the same, states as follows:
1. The current expert disclosure deadlines are:
a. April 5, 2024 for Plaintiff’s Affirmative Expert Disclosure
b. May 7, 2024 for Defendants’ Affirmative and Rebuttal Disclosures
c. June 4, 2024 for Plaintiff’s Rebuttal Disclosures
d. July 1, 2024 Discovery Cut-off
e. August 9, 2024 Dispositive/702 Motions Deadline
2. In addition to this matter, there are four other lawsuits against the Defendants also
pending (Notice of Related Cases, ECF 2).
Case No. 1:23-cv-01339-RM-STV Document 61 filed 03/07/24 USDC Colorado pg 1 of 3
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3. The parties have sent discovery requests and are currently waiting for those
responses, which are due on March 11. Defendant Fort Collins has requested a 16 -
day extension to provide their responses, through March 27.
4. Plaintiff’s is expecting information in the discovery responses that he’d like his retained
experts to be able to review as part of producing their reports.
5. Plaintiff proposes a 20-day extension to the expert disclosure and all other subsequent
discovery and motions deadlines:
a. April 26, 2024 for Plaintiff’s Affirmative Expert Disclosure
b. May 28, 2024 for Defendants’ Affirmative and Rebuttal Disclosures
c. June 25, 2024 for Plaintiff’s Rebuttal Disclosures
d. July 22, 2024 Discovery Cut-off and 702 and 704 Motions
e. August 30, 2024 Dispositive Motion Deadline
6. Conferral: Counsel has conferred with counsel for Defendants and is authorized to
state that they do not oppose the relief requested herein.
7. The extension will not unduly delay these proceedings or otherwise interfere with the
administration of justice.
8. No party will be prejudiced by the relief sought herein.
WHEREFORE Plaintiff Derrick Groves, respectfully requests an extension to the
discovery deadlines.
Respectfully submitted this 7th day of March, 2024.
/s/ Sarah Schielke
Sarah Schielke
The Life & Liberty Law Office LLC
1055 Cleveland Avenue
Loveland, CO 80537
Telephone: (970) 493-1980
Case No. 1:23-cv-01339-RM-STV Document 61 filed 03/07/24 USDC Colorado pg 2 of 3
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FAX: (970) 797-4008
Email: sarah@lifeandlibertylaw.com
Attorney for Plaintiff Derrick Groves
CERTIFICATE OF SERVICE
This is to certify that on March 7, 2024, a true and accurate copy of the foregoing Motion
has been sent to the following parties by PACER/ECF:
Mark Ratner
Robert Weiner
Katherine Hoffman
Hall & Evans, LLC
Attorney for Defendants City of Fort Collins
and Sergeant Allen Heaton
Yulia Nikolaevskya
Jonathan Abramson
SGR, LLC
Attorneys for Jason Haferman
Derrick Groves
Plaintiff
/s/ Madie Baskin
Madie Baskin,
Paralegal for Sarah Schielke
Case No. 1:23-cv-01339-RM-STV Document 61 filed 03/07/24 USDC Colorado pg 3 of 3