HomeMy WebLinkAbout2021-cv-2063 - City of Fort Collins v. Open International, et al. - 381 - Open's Motion to Extend Deadline1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No.: 21-cv-02063-CNS-SBP
CITY OF FORT COLLINS,
Plaintiff/Counterclaim Defendant,
v.
OPEN INTERNATIONAL, LLC,
Defendant/Counterclaim Plaintiff,
and
OPEN INVESTMENTS, LLC,
Defendant.
______________________________________________________________________________
OPEN INTERNATIONAL LCC’S MOTION TO EXTEND DEADLINE BY WHICH TO
RESPOND TO MOTION TO REGISTER JUDGMENT
______________________________________________________________________________
Defendant Open International LLC moves for a one-week extension of the deadline by
which it must respond to the City of Fort Collins’s (City’s) Motion for an Order Allowing
Registration of its Judgment Against Open International LLC for Enforcement in Other Districts
(Dkt. No. 380) (hereafter, “Motion to Register Judgment”). Defendant has conferred with
counsel for the City and can confirm that the City has no objection to the relief requested herein.
The City filed its Motion to Register Judgment on December 20, making Defendant’s
Response due 21 days later, on January 10. See Dist. Colo. Local Rule 7.1. The holidays, and
holiday-related travel of both Defendant personnel and undersigned attorneys, have made
Case No. 1:21-cv-02063-CNS-SBP Document 381 filed 01/08/25 USDC Colorado
pg 1 of 3
2
adhering to that deadline especially difficult. A one-week extension will abate that time crunch
and provide the Court a fulsome response.
CONCLUSION
For the foregoing reasons, Defendant respectfully requests a one-week extension of the
deadline by which to respond to the City’s Motion to Register Judgment.
Dated: January 8, 2025 Respectfully submitted,
/s/ Jeffrey Sandman___________
Laurie.Daniel@webbdaniel.law
Jeff.Sandman@webbdaniel.law
WEBB DANIEL FRIEDLANDER LLP
75 14th Street NE
Suite 2450
Atlanta, Georgia 30309
Attorneys for Open International LLC
Case No. 1:21-cv-02063-CNS-SBP Document 381 filed 01/08/25 USDC Colorado
pg 2 of 3
3
CERTIFICATE OF CONFERAL
Pursuant to Local Rule 7.1(a), counsel for Open International LLC conferred with
counsel for Plaintiff regarding the relief requested by this Motion. Plaintiff does not oppose the
relief requested herein.
/s/ Jeffrey Sandman
Jeffrey Sandman
Webb Daniel Friedlander LLP
CERTIFICATE OF SERVICE
I hereby certify that on this January 8th, 2025, the foregoing was electronically filed with
the Clerk of Court using the Court’s electronic filing system and that a copy of the foregoing was
sent to all counsel of record via same in compliance with the Federal Rules of Civil Procedure
and the Local Rules of this Court.
/s/ Jeffrey Sandman
Jeffrey Sandman
Webb Daniel Friedlander LLP
Case No. 1:21-cv-02063-CNS-SBP Document 381 filed 01/08/25 USDC Colorado
pg 3 of 3