HomeMy WebLinkAbout2023-cv-2187 - Kulas v. City of Fort Collins, et al. - 035 - Plaintiff's Unopp Mot 35-day Extension re Discovery Deadlines 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 23-cv-02187-KAS
ANDRU KULAS,
Plaintiff,
v.
CITY OF FORT COLLINS;
KEVIN PARK; and
AVERY HANZLICEK.
Defendants.
UNOPPOSED MOTION FOR 35-DAY EXTENSION TO DISCOVERY DEADLINES
Plaintiff Andru Kulas, by and through his attorneys, respectfully requests
(approximately) 35-day extensions to the remaining discovery deadlines in this
case, and as good cause therefore, states as follows:
1. Due to scheduling conflicts between counsel and deponents, at least one deposition
(Defendant Kevin Park’s) has already had to be scheduled after the discovery cutoff
in this case, currently scheduled as July 30.
2. Further, one of Plaintiff’s experts expected to be endorsed needs to see training
documents that were requested in Plaintiff’s first set of discovery requests to the City
for writing his report, and those documents are not expected to be disclosed by the
City until May 6 (four days after the current expert disclosure deadline).
3. The current discovery deadlines set forth in the Court’s March 5 Minute Order [ECF
34] are:
Case No. 1:23-cv-02187-CNS-KAS Document 35 filed 04/25/24 USDC Colorado pg 1 of 3
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a. May 2, 2024 for Affirmative Experts
b. June 2, 2024 for Defense Experts
c. July 8, 2024 for Plaintiff’s Rebuttal Experts
d. 30 days from July 8, 2024 for 702 Motions
e. August 2, 2024 for Discovery Cutoff
f. September 16, 2024 for Dispositive Motions
4. Plaintiff requests an (approximately, as some dates fell on weekends and were moved
to the following Monday) 35-day extension to these deadlines. The new deadlines
would be:
a. Plaintiff’s Affirmative Experts: June 10, 2024
b. Defense Affirmative and Rebuttal Experts: July 10, 2024
c. Plaintiff’s Rebuttal Experts: August 12, 2024
d. Rule 702 Motions: No later than 30 days from Aug 12
e. Discovery Cutoff: September 10, 2024
f. Dispositive Motions: October 25, 2024
5. The extension will not unduly delay these proceedings or otherwise interfere with the
administration of justice.
6. No party will be prejudiced by the relief sought herein.
WHEREFORE the parties respectfully request that the Court adopted as Order
of the Court the amended discovery deadlines proposed above for good cause
shown.
Respectfully submitted this 25th day of April, 2024.
Case No. 1:23-cv-02187-CNS-KAS Document 35 filed 04/25/24 USDC Colorado pg 2 of 3
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THE LIFE & LIBERTY LAW OFFICE LLC
s/ Sarah Schielke
Sarah Schielke
Counsel for Plaintiff
The Life & Liberty Law Office LLC
1055 Cleveland Avenue
Loveland, CO 80537
P: (970) 493-1980
E: sarah@lifeandlibertylaw.com
CERTIFICATE OF SERVICE
I hereby certify that on the 25th day of April, 2024, I electronically filed the
foregoing with the Clerk of Courts using the CM/ECF system which will send notification
of such filing to the following e-mail addresses:
ratnerm@hallevans.com
Attorney for Defendants
/s/ Madie Baskin
Madie Baskin
Case No. 1:23-cv-02187-CNS-KAS Document 35 filed 04/25/24 USDC Colorado pg 3 of 3