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HomeMy WebLinkAbout2017CV1177 - Mcgrath V. Fcps Officer Nick Rogers - 043 - Plaintiff's Unopposed Motion For Extension Of Time To Respond To Motion For Summary JudgmentIN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 17-CV-01177-LTB-NYW DAKOTA TYLER MCGRATH, Plaintiff, v. FORT COLLINS POLICE SERVICES OFFICER NICK RODGERS, in his individual capacity, Defendant. PLAINTIFF’S UNOPPOSED MOTION FOR 14-DAY EXTENSION OF TIME, UNTIL JULY 11, 2018, TO RESPOND TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT Plaintiff, Dakota McGrath, by and through counsel, Anthony Viorst of the Viorst Law Offices, P.C., hereby moves for a 14-day extension of time, until July 11, 2018, to file a Response to Defendant’s Motion for Summary Judgment, and states as follows: Certification Undersigned counsel certifies that he has conferred with opposing counsel, Matthew Hegarty, and that he does not oppose the instant motion. 1. Defendant filed his Motion for Summary Judgment on June 6, 2018. Plaintiff’s response is due June 27, 2018. 2. The Plaintiff unexpectedly passed away on May 21, 2018. 3. Due the complicated nature of this case and the Plaintiff’s unexpected death compounding the complexity, Plaintiff’s counsel requests an additional 14-day extension of time to complete a response. 4. It is stipulated that Defendant's reply deadline will also be extended by two weeks, until July 25, 2018. WHEREFORE, for the foregoing reasons, Plaintiff moves for an unopposed 14-day extension of time, until July 11, 2018 to file a response to Defendant’s Motion for Summary Judgment. Case 1:17-cv-01177-LTB-NYW Document 43 Filed 06/22/18 USDC Colorado Page 1 of 2 2 Dated this 22 nd day of June, 2018. THE VIORST LAW OFFICES, P.C. [Original signature on file at Viorst Law Offices, P.C.] s/ Anthony Viorst Anthony Viorst, #18508 Viorst Law Offices, PC 950 South Cherry Street, Suite 300 Denver, CO 80246 Telephone: (303) 759-3808 Facsimile: (303) 333-7127 E-mail: tony@hssspc.com Attorney for Plaintiff CERTIFICATE OF SERVICE I hereby certify that on this 22 nd day of June, 2018, I electronically filed a true and correct copy of the above and foregoing PLAINTIFF’S UNOPPOSED MOTION FOR 14-DAY EXTENSION OF TIME, UNTIL JULY 11, 2018, TO RESPOND TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT with the Clerk of the Court using the CM/ECF system, which will send notification of such filing to the following e-mail address(es): Matthew J. Hegarty, Esq. Thomas J. Lyons, Esq. Hall & Evans, LLC 1001 Seventeenth Street, Suite 300 Denver, CO 80202 [Original signature on file at Viorst Law Offices, P.C.] s/ Michelle Spadavecchia Legal Assistant Case 1:17-cv-01177-LTB-NYW Document 43 Filed 06/22/18 USDC Colorado Page 2 of 2