HomeMy WebLinkAbout2023-cv-1344 - Sever v. City of Fort Collins, et al. - 068 - Plaintiff's Unopp Mot Amend Scheduling Order to Extend Discovery Deadline 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 23-CV-01344-NYW-NRN
CARL SEVER,
Plaintiff,
v.
CITY OF FORT COLLINS, and
JASON HAFERMAN,
Defendants.
PLAINTIFF’S UNOPPOSED MOTION TO AMEND SCHEDULING ORDER [ECF 58]
TO EXTEND DISCOVERY DEADLINES
Plaintiff Carl Sever, 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. May 17, 2024 for Plaintiff’s Affirmative Expert Disclosure
b. June 18, 2024 for Defendants’ Affirmative and Rebuttal Disclosures
c. July 16, 2024 for Plaintiff’s Rebuttal Disclosures
d. August 12, 2024 Discovery Cut-off and 702 and 704 Motions
e. September 20, 2024 Dispositive Motion Deadline
2. In addition to this matter, there are four other lawsuits against the Defendants also
pending (Notice of Related Cases, ECF 2).
3. Plaintiff’s counsel had a personal family emergency and tragedy this month that
completely disrupted her ability to work for a ten -day stretch. On May 9 her stepmom
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was admitted to the ICU at Poudre Valley Hospital and had to be put on a ventilator.
On May 15, undersigned counsel and her family had to make the decision to remove
her from the ventilator. Counsel spent the next 5 days at the hospital in the ICU with
her stepmom and family. Her stepmom passed away the evening of May 20.
4. Plaintiff’s counsel did confer with opposing counsel ahead of the May 17 affirmative
expert disclosure deadline to confirm they were agreeable to some brief extension of
it (with its duration to be figured out on the other side of this family emergency) in light
of counsel’s circumstances.
5. Counsel has been endeavoring to get caught up on all the work she has fallen behind
on due to these unforeseeable events and has conferred with defense counsel again
to confirm agreement as to a 3-week extension on all the deadlines across all 5 cases.
6. Plaintiff proposes a 3-week extension to the expert disclosure and all other
subsequent discovery and motions deadlines:
a. June 7, 2024 for Plaintiff’s Affirmative Expert Disclosure
b. July 9, 2024 for Defendants’ Affirmative and Rebuttal Disclosures
c. August 6, 2024 for Plaintiff’s Rebuttal Disclosures
d. September 3, 2024 Discovery Cut-off and 702 and 704 Motions
e. October 11, 2024 Dispositive Motion Deadline
7. Conferral: Counsel has conferred with counsel for Defendants and is authorized to
state that they do not oppose the relief requested herein.
8. The extension will not unduly delay these proceedings or otherwise interfere with the
administration of justice.
9. No party will be prejudiced by the relief sought herein.
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WHEREFORE Plaintiff Carl Sever, respectfully requests an extension to the discovery
deadlines.
Respectfully submitted this 28th day of May, 2024.
/s/ Sarah Schielke
Sarah Schielke
The Life & Liberty Law Office LLC
1055 Cleveland Avenue
Loveland, CO 80537
Telephone: (970) 493-1980
FAX: (970) 797-4008
Email: sarah@lifeandlibertylaw.com
Attorney for Plaintiff Carl Sever
CERTIFICATE OF SERVICE
This is to certify that on May 28, 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
Carl Sever
Plaintiff
/s/ Madie Baskin
Madie Baskin,
Paralegal for Sarah Schielke
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