HomeMy WebLinkAbout2023-cv-1343 - Elias v. City of Fort Collins, et al. - 093 - Haferman Unopp Mot Extension of Time to Respond to 2d Am ComplaintIN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 23-cv-01343-GPG-KAS
HARRIS ELIAS,
Plaintiff,
v.
CITY OF FORT COLLINS,
JASON HAFERMAN, and
SERGEANT ALLEN HEATON,
Defendants.
DEFENDANT HAFERMAN’S UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE RESPONSE TO PLAINTIFF’S SECOND AMENDED COMPLAINT
Defendant Jason Haferman (“Defendant Haferman”), in his individual capacity, by and
through counsel of record, Jonathan M. Abramson and Yulia Nikolaevskaya of SGR, LLC., hereby
submits his Unopposed Motion for Extension of Time to File Response to Plaintiff’s Second
Amended Complaint as follows.
CERTIFICATION PURSUANT TO D.C.COLO.LCivR 7.1(a)
Undersigned counsel, Yulia Nikolaevskaya, conferred with Plaintiff’s counsel, Sarah
Schielke (“Ms. Schielke”) via email on April 25, 2024, concerning the relief requested in this
Motion. Ms. Schielke has indicated that the Motion is Unopposed.
Case No. 1:23-cv-01343-GPG-KAS Document 93 filed 04/26/24 USDC Colorado pg 1 of 4
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MOTION
1. Plaintiff filed his Second Amended Complaint on April 15, 2024 [ECF 88].
2. Defendant Haferman’s response to Plaintiff’s Second Amended Complaint is
currently due April 29, 2024.
3. Because of the voluminous nature of Plaintiff’s allegations which have increased
in Plaintiff’s Second Amended Complaint, additional time is needed to prepare Defendant
Haferman’s response.
4. In addition to working on response to Plaintiff’s Second Amended Complaint,
during the week of April 15, 2024, undersigned counsel for Defendant Haferman took two
depositions in M.P. v Poudre School District, et al, Civil Action No. 22-cv-00220-PAB-KLM, a
U.S. District Court for the District of Colorado case, one deposition in Muller v Waggoners
Trucking, et al, Civil Action No. 23-cv-00513-CNS-JPO, , a U.S. District Court for the District of
Colorado case, and numerous meetings with clients to prepare for upcoming depositions. During
the week of April 22, 2024, the undersigned counsel for Defendant Haferman was also engaged in
taking, appearing and defending fifteen (15) depositions in Chaffee County District Court case
2023CV030010 - Athanas, Ellis v. Orth, Corey et al. Multiple depositions were taken in Salida,
Colorado. In addition, on April 29, 2024, the undersigned counsel is scheduled to participate in a
mediation in a U.S. District Court for the District of Colorado case.
5. Therefore, Defendant Haferman requests a fourteen (14) day extension of time to
file his response to Plaintiff’s Second Amended Complaint.
6. The extension will not unduly delay these proceedings or otherwise interfere with
the administration of justice.
Case No. 1:23-cv-01343-GPG-KAS Document 93 filed 04/26/24 USDC Colorado pg 2 of 4
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7. Defendant Haferman has not previously requested an extension of time to file his
response to Plaintiff’s Second Amended Complaint.
8. Pursuant to D.C.COLO.LCivR 6.1(c), undersigned counsel for Defendant
Haferman certifies that a copy of this Motion has been provided to Defendant Haferman.
WHEREFORE, Defendant Haferman, in his individual capacity, respectfully requests a
fourteen (14) day extension of time within which to file a response to Plaintiff’s Second Amended
Complaint up to and including to May 13, 2024.
Dated this 26th day of April 2024.
SGR, LLC
s/ Jonathan M. Abramson
Jonathan M. Abramson
Yulia Nikolaevskaya
3900 East Mexico Ave., #700
Denver, Colorado 80210
Phone: 303-320-0509
Email: jabramson@sgrllc.com
Email: jnikolaevskaya@sgrllc.com
Attorneys for Defendant Haferman
Case No. 1:23-cv-01343-GPG-KAS Document 93 filed 04/26/24 USDC Colorado pg 3 of 4
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CERTIFICATE OF SERVICE
I hereby certify that on the 26th day of April 2024, I electronically filed the foregoing with
the Clerk of Court using the CM/ECF system which will send notification of such filing to the
following e-mail addresses:
Sarah Schielke, Esq. (sarah@lifeandlibertylaw.com)
ATTORNEY FOR PLAINTIFFS
Robert S. Ratner, Esq. (ratnerm@hallevans.com)
Robert A. Weiner, Esq. (weinerr@hallevans.com)
Katherine N. Hoffman, Esq. (hoffmank@hallevans.com)
ATTORNEYS FOR DEFENDANTS CITY OF FORT COLLINS, SERGEANT ALLEN HEATON
and I hereby certify that I have mailed or served the document or paper to the following non -
CM/ECF participants in the manner (mail, hand delivery, etc.) indicated by the non-participant’s
name: N/A
Defendant Jason Haferman
(c/o SGR, LLC; Attn: Jonathan M. Abramson, Esq.; jabramson@sgrllc.com)
s/ Taylor Will
Legal Secretary
SGR, LLC
Case No. 1:23-cv-01343-GPG-KAS Document 93 filed 04/26/24 USDC Colorado pg 4 of 4