HomeMy WebLinkAbout2024-cv-2336 - O’Ryan v. City of Fort Collins - 015 - Defendant's Unopposed Motion for Extension Respond to ComplaintIN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 24-cv-02336-RMR-NRN
LAURELEI O’RYAN,
Plaintiff,
v.
CITY OF FORT COLLINS,
Defendant.
DEFENDANT’S UNOPPOSED MOTION FOR A FOUR-DAY EXENSION OF TIME TO
RESPOND TO COMPLAINT
Defendant, City of Fort Collins, by and through its counsel, Kendra K. Smith, Esq.
and Danyelle Semjonovs, Esq., of Hall & Evans, L.L.C., respectfully submits this
Unopposed Motion for a Four (4) Day Extension of Time, up to and including Monday,
October 28, 2024, to Respond to the Complaint, as follows:
1. Pursuant to D.C.COLO.LCivR 7.1, prior to filing this Motion, the
undersigned counsel conferred with counsel for Plaintiff who does not object to the relief
sought herein. Thus, this motion is unopposed.
2. Plaintiff filed a Complaint on August 23, 2024.
3. Defendant filed a Waiver of Service of Process on September 6, 2024, and
its Answer or other response to the Complaint was deemed due 60 days after August 23,
2024, or October 22, 2024.
Case No. 1:24-cv-02336-RMR-NRN Document 15 filed 10/21/24 USDC Colorado pg 1 of 3
4. Counsel for Defendant was recently retained in this matter, around October
14, 2024, and requires a brief period of time to speak with the client contacts for
Defendant, prior to filing Defendant’s responsive pleading.
5. This Court has discretion to grant this motion pursuant to Fed. R. Civ. Pro.
6(b)(1)(A).
6. There is good cause for the proposed extension to allow counsel to gather
the necessary and appropriate factual information prior to filing the responsive pleading.
7. As counsel for Plaintiff and Defendant have conferred and there is no
opposition to the relief sought herein, neither party will be prejudiced by this request for
an extension of time.
WHEREFORE, Defendant, City of Fort Collins, respectfully requests this Court
GRANT this Unopposed Motion for a Four-Day Extension of Time, to allow Defendant to
file its response to Plaintiff’s Complaint, up to and including Monday, October 28, 2024.
Respectfully submitted this 21st day of October, 2024.
s/ Danyelle Semjonovs
Danyelle Semjonovs, Esq.
Kendra K. Smith, Esq.
Hall & Evans, L.L.C.
1001 Seventeenth Street, Suite 300
Denver, CO 80202
(303) 628-3300
smithk@hallevans.com
semjonovsd@hallevans.com
ATTORNEY FOR DEFENDANT CITY
OF FORT COLLINS
Case No. 1:24-cv-02336-RMR-NRN Document 15 filed 10/21/24 USDC Colorado pg 2 of 3
CERTIFICATE OF SERVICE (CM/ECF)
I hereby certify that on the 21st day of October, 2024, I electronically filed the
foregoing with the Clerk of Court using the CM/EFC system which will send notification of
such filing to the following e-mail addresses:
Robert M. Liechty
ROBERT LIECHTY PC
1800 Gaylord Street
Denver, Colorado 80206
(303) 861-5300
rliechty@crossliechty.com
Attorney for Plaintiff
s/ Erica Cameron
Erica Cameron, Legal Assistant
Hall & Evans, L.L.C.
Case No. 1:24-cv-02336-RMR-NRN Document 15 filed 10/21/24 USDC Colorado pg 3 of 3