HomeMy WebLinkAbout2018CV3112 - Sean Slatton V. Fort Collins Police Department, Todd Hopkins, Brandon Barnes And John Hutto - 101 - Unopposed Motion For Extension Of Time To File Plaintiff's Consolidated Response1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 1:18-cv-03112-RBJ-STV
SEAN SLATTON,
Plaintiff,
v.
TODD HOPKINS,
BRANDON BARNES,
JOHN HUTTO, and
FORT COLLINS POLICE DEPARTMENT
Defendants.
______________________________________________________________________________
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE PLAINTIFF’S
CONSOLIDATED RESPONSE TO DEFENDANTS’ MOTIONS TO DISMISS [Docs. 96
and 98]
______________________________________________________________________________
Plaintiff, by and through his attorneys, David A. Lane and Helen Oh, hereby submit the
following UNOPPOSED Motion for Extension of Time to File Plaintiff’s Consolidated
Response to Defendants’ Motions to Dismiss [Docs. 96 and 98] and states as follows:
1. Defendant Hopkins filed his Motion to Dismiss on January 13, 2020 [Doc. 96].
2. Defendants Fort Collins, Colorado, Brandon Barnes, and John Hutto filed their
Motion to Dismiss on January 16, 2020 [Doc. 98].
3. Plaintiff’s counsel is diligently preparing their Consolidated Response to
Defendants’ Motions to Dismiss but need additional time to finalize the consolidated response.
4. Counsel for Plaintiffs-Appellees, David A. Lane, in addition to the usual press of
business, has spent a considerable amount of time working on a new sealed case he was recently
appointed to in Western District of Texas; on January 20, he attended and prepared for oral
arguments for Jones v. Manriquez, et al., Case No. 19-1144; Mr. Lane was out of town from
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January 24-26 on a pre-planned trip for an unrelated matter, and on January 27, he testified in
front of the Colorado State Senate regarding the death penalty repeal.
5. Counsel for Plaintiff, Helen Oh, will be primarily responsible for drafting the
Consolidated Response to Defendants’ Motions to Dismiss. In addition to the usual press of
business, she spent a considerable amount of time drafting a mediation statement and attended
mediation for a pre-litigation case Patnode v. City of Fort Collins on February 3, 2020. She is
also drafting discovery requests in Flores v. State of Colorado, et al., and a response to a Motion
for Summary Judgment in another matter, Briones v. Adams County, et al.
6. No party will be prejudiced by the relief sought herein.
CERTIFICATION PURSUANT TO D.C.COLO. LCivR. 7.1
7. Counsel for Plaintiff, Helen Oh, hereby certifies that she conferred with counsel
for Defendants via email on February 4, 2020. Counsel for Defendants stated that Defendants do
not oppose the relief requested herein.
CERTIFICATION PURSUANT TO D.C.COLO. LCivR. 6.1(c)
8. Counsel for Plaintiff, Helen Oh, certifies that a copy of this Motion will be served
contemporaneously on Plaintiffs upon the filing of this Motion.
WHEREFORE, Plaintiffs respectfully request that the Court grant his UNOPPOSED
Motion for Extension of Time to File Consolidated Response to Defendants’ Motions to Dismiss
[Docs. 96 and 98], up to and including February 20, 2020, and for any other relief deemed just
and proper.
Respectfully submitted this 5th
day of February 2020.
KILLMER, LANE & NEWMAN, LLP
s/ Helen Oh
________________________
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David A. Lane
Helen Oh
1543 Champa Street, Suite 400
Denver, Colorado 80202
Phone: (303) 571-1000
dlane@kln-law.com
hoh@kln-law.com
Counsel for Plaintiffs
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CERTIFICATE OF SERVICE
I certify that on this 5th
day of February, 2020 I filed a true and correct copy of the
foregoing via CM/ECF which will generate e-mailed notice to the following:
Marni Nathan Kloster
Nicholas C. Poppe
Nathan Dumm & Mayer, PC
7900 E. Union Ave., Ste 600
Denver, CO 80237-2776
303-691-3737
MKloster@ndm-law.com
NPoppe@ndm-law.com
Attorney for Defendant Todd Hopkins
Mark Ratner
Hall & Evans, LLC
1001 17th
Street, Ste 300
Denver, CO 80202
303-628-3300
ratnerm@hallevans.com
Counsel for Ft. Collins Defendants
s/ Jamie Akard
Paralegal
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