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HomeMy WebLinkAbout2017CV30903 - Ilse Westphal V. City Of Fort Collins, Et Al - 020 - City's Motion For Extension Of Time To ReplyDISTRICT COURT, LARIMER COUNTY, COLORADO 201 LaPorte Avenue, Suite 100 Fort Collins, CO 80521-2761 Phone: 970-498-6100 ______________________________________________ Plaintiff: ILSE G. WESTPHAL v. Defendants: ANTHONY JOHN JANSA; JANSA TRUCKING, LLC, a Colorado Limited Liability Company; JANSA TRUCKING, LLC, a North Dakota Limited Liability Company; THE CITY OF FORT COLLINS, a Colorado municipal corporation ______________________________________________ Attorneys for Defendant City of Fort Collins Peter C. Middleton, Esq., #32335 HALL & EVANS, L.L.C. 1001 17th St., Suite 300 Denver, CO 80202 303-628-3300 303-628-3368 / Fax middletonp@hallevans.com John Duval, #10185 Deputy City Attorney City of Fort Collins 300 LaPorte Avenue Fort Collins, CO 80522-0580 970-416-2488 jduval@fcgov.com COURT USE ONLY __________________________ Case No. 2017-CV-030903 Div. 3C DEFENDANT CITY OF FORT COLLINS’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE ITS REPLY IN SUPPORT OF MOTION TO DISMISS DATE FILED: December 22, 2017 12:11 PM FILING ID: 5416DC7122BF4 CASE NUMBER: 2017CV30903 2 Defendant, City of Fort Collins, by and through its counsel, submits the following unopposed Motion for Extension of Time to File its Reply in Support of Motion to Dismiss: CERTIFICATION – C.R.C.P. 121 Counsel for Defendant spoke to counsel for Plaintiff by telephone on December 22, 2017 to confer on this motion. Plaintiff’s counsel has no objection to the relief requested herein. 1. No trial date is currently set. 2. Defendant filed its motion to dismiss on November 30, 2017. 3. Plaintiff filed his response on December 19, 2017. 4. Defendant’s reply is due December 26, 2017. Due to the holidays and out-of-town travel, Defendant requests an extension up to and including January 5, 2018, to file its reply. This motion is not brought for purposes of delay and will not prejudice any party. WHEREFORE, Defendant respectfully requests this Court allow Defendant until January 5, 2018 in which to file its Reply in Support of Motion to Dismiss. Dated: December 22, 2017 /s/ Peter C. Middleton Peter C. Middleton, Esq., #32335 of HALL & EVANS, L.L.C. ATTORNEYS FOR DEFENDANT CITY OF FORT COLLINS /s/ John R. Duval John R. Duval, Esq., #10185 Deputy City Attorney of City of Fort Collins ATTORNEY FOR DEFENDANT CITY OF FORT COLLINS In accordance with C.R.C.P. 121 § 1-26(7), a printed copy of this document with original signatures is being maintained by the filing party and will be made available for inspection by other parties or the Court upon request. 3 CERTIFICATE OF SERVICE I hereby certify that on this 22nd day of December, 2017, I electronically filed and served the foregoing DEFENDANT CITY OF FORT COLLINS’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE ITS REPLY IN SUPPORT OF MOTION TO DISMISS via the Colorado Courts E-Filing system upon the following: David M. Herrera, Esq. HERMS & HERRERA, L.L.C. 3600 South College Avenue, Suite 204 Fort Collins, CO 80525 david@hhlawoffice.com Counsel for Plaintiff James M. Meseck, Esq., #33021 Joseph W. Mark, #48644 White and Steele, P.C. 600 17th Street, Suite 600N Denver, CO 80202 jmeseck@wsteele.com jmark@wsteele.com Counsel for Anthony J. Jansa and Jansa Trucking, LLC Original Signature on File /s/Julie Eaglesham Julie Eaglesham