HomeMy WebLinkAbout2023-cv-1341 - Erbacher v. City Of Fort Collins, et al. - 101 - Pl's Unopp Motion Amend Scheduling Order 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 23-cv-1341-CNS-NRN
CODY ERBACHER,
Plaintiff,
v.
CITY OF FORT COLLINS, and
JASON HAFERMAN,
Defendants.
PLAINTIFF’S UNOPPOSED MOTION TO AMEND REMAINING SCHEDULING
ORDER DEADLINES
Plaintiff Cody Erbacher, by and through his attorney, file this Unopposed Motion to
Amend Remain Scheduling Order Deadlines and in support of the same respectfully
states as follows:
CERTIFICATE OF CONFERRAL
Plaintiff’s counsel conferred with both sets of defense counsel via email regarding
the relief requested herein; all have indicated no objection. Counsel also certifies that a
copy of this motion was served on Plaintiff via email.
1. The extensions to the remaining deadlines in the scheduling order sought herein was
previously discussed with the Court at the hearing held on December 5, 2024.
2. There was a pending motion at that time for the 702 motions deadline to be extended
to March 7 to align with the 702 motions deadline in 3 of the other 5 associated cases.
Case No. 1:23-cv-01341-CNS-NRN Document 101 filed 12/10/24 USDC Colorado
pg 1 of 3
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3. Plaintiff’s counsel noted with the ongoing discovery disputes in this matter that it would
be necessary and appropriate to extend the other two remaining deadlines in this
matter (discovery cutoff and dispositive motions) to February 7 and March 7
respectively, to align with the other 3 cases and to permit the time needed for
remaining ongoing discovery.
4. The Court instructed counsel to confer and file a written motion to that effect to
accomplish the remaining extensions discussed. Counsel has conferred and this is
that motion.
WHEREFORE the Plaintiff respectfully requests that the discovery cut-off in this case
be extended to February 7, 2025 and the dispositive motions deadline be extended to
March 7, 2025.
Respectfully submitted this 10th day of December, 2024.
THE LIFE & LIBERTY LAW OFFICE
/s/ Sarah Schielke
Sarah Schielke
The Life & Liberty Law Office LLC
1055 Cleveland Avenue
Loveland, CO 80537
P: (970) 493-1980
F: (970) 797-4008
E: sarah@lifeandlibertylaw.com
Counsel for Plaintiff
Case No. 1:23-cv-01341-CNS-NRN Document 101 filed 12/10/24 USDC Colorado
pg 2 of 3
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CERTIFICATE OF SERVICE
This is to certify that on December 10, 2024, a true and accurate copy of the foregoing
Motion has been sent to the following parties by PACER/ECF:
Mark Ratner
Hall & Evans, LLC
Attorney for Defendants City of Fort Collins
Yulia Nikolaevskya
Jonathan Abramson
SGR LLC
Attorneys for Defendant Jason Haferman
Cody Erbacher
Plaintiff /s/ Sarah Schielke
Case No. 1:23-cv-01341-CNS-NRN Document 101 filed 12/10/24 USDC Colorado
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