HomeMy WebLinkAbout2017CV884 - Chayce Anderson V. Fcps Officer Jason Shutters - 112 - Unopposed Motion To Conduct Depositon Of Incarcerated Person3439103.1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 17-cv-00884-CMA-STV
CHAYCE AARON ANDERSON,
Plaintiff,
v.
JASON SHUTTERS,
Defendant.
_____________________________________________________________________
DEFENDANT JASON SUTTHER’S UNOPPOSED MOTION TO CONDUCT A
DEPOSITION OF AN INCARCERATED INMATE PLAINTIFF PURSUANT TO FED. R.
CIV. P. 30(a)(2)(B)
______________________________________________________________________
Defendant Jason Shutters, by and through his attorney, Hall & Evans, L.L.C.,
submits the following as his Motion to Conduct A Deposition of an Incarcerated Inmate
Plaintiff, and as grounds therefor state as follows:
Certificate of Compliance with D.C.COLO.LCivR 7.1(A)
Pursuant to D.C.COLO.LCivR 7.1(A), the undersigned counsel conferred with
counsel for the Plaintiff. Plaintiff does not oppose the requested relief.
1. Pursuant to Fed. R. Civ. P. 30(a)(2)(B), an order from this Court is required
for Defendant to conduct the deposition of the Plaintiff, who is incarcerated by the
Colorado Department of Corrections. Plaintiff is currently located at the Arkansas Valley
Correctional Facility, 12750 CO-96, Ordway, CO 81034.
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2. Defendant respectfully requests this Court issue an order allowing
Defendant to depose Plaintiff at his current correctional facility or any subsequent
correctional facility where he may be moved after the entry of an appropriate order.
WHEREFORE, Defendant respectfully requests this Court issue an order allowing
the deposition of Plaintiff pursuant to F.R.C.P. 30(a)(2)(B), and for all other and further
relief as this Court deems necessary.
Dated: December 21, 2018.
Respectfully Submitted
Duly Signed original in the file located at
Hall & Evans, LLC
/s/ Mark S. Ratner
Mark S. Ratner, #38517
Hall & Evans, LLC
1001 Seventeenth Street, Suite 300
Denver, Colorado 80202
Attorneys for Defendant Jason
Shutters
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CERTIFICATE OF SERVICE (CM/ECF)
I hereby certify that on this 21st of December, 2018, I served via email the
foregoing DEFENDANT JASON SUTTHER’S UNOPPOSED MOTION TO CONDUCT A
DEPOSITION OF AN INCARCERATED INMATE PLAINTIFF PURSUANT TO FED. R.
CIV. P. 30(a)(2)(B) to the following:
Ll. Rhyddid Watkins, Esq.
Christopher J. Casolaro, Esq.
Travis S. Jordan, Esq.
FAEGRE BAKER DANIELS LLP
1700 Lincoln Street, Suite 3200
Denver, CO 80203
Heather Campbell Burgess, Esq.
FAEGRE BAKER DANIELS LLP
311 South Wacker Drive
Suite 4400
Chicago, IL. 60606-6622
s/ Rochelle Gurule
Legal Assistant to Mark S. Ratner, Esq.
Of Hall & Evans, LLC
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