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HomeMy WebLinkAbout2018CV3112 - Sean Slatton V. Fort Collins Police Department, Todd Hopkins, Brandon Barnes And John Hutto - 110 - Defendants' Joint Unopposed Motion For Extension Of Time To Submit Reply Briefs In Support Of Their Motions To DismissIN 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, CITY OF FORT COLLINS Defendants. DEFENDANTS’ JOINT UNOPPOSED MOTION FOR EXTENSION OF TIME TO SUBMIT REPLY BRIEFS IN SUPPORT OF THEIR MOTIONS TO DISMISS [ECF 96 & 98] The Defendants, by and through their respective counsel, hereby submit their Unopposed Joint Motion for Extension of Time to Submit Reply Briefs in Support of their Motions to Dismiss, and in support thereof states as follows: 1. The Defendants’ current deadline to submit their reply briefs in support of their motions to dismiss is March 16, 2020. 2. The undersigned has conferred with counsel for the Plaintiff, who does not oppose the relief sought in this Motion. 3. Unfortunately the March 2, 2020 filing of Plaintiff’s response brief fell during a particularly busy time for the undersigned. In addition to preparing for a final pre-trial conference in an ADA case in front of Judge Wang, the undersigned had to travel to Lamar, CO Case 1:18-cv-03112-RBJ-STV Document 110 Filed 03/12/20 USDC Colorado Page 1 of 4 -2- for another case this week. As a result, the undersigned has not had sufficient time to prepare a reply to Plaintiff’s thirty-page response, nor confer with the undersigned’s client. 4. The undersigned thus requests a one-week extension, up through and including March 23, 2020, in which to submit a reply brief. 5. This is the first request by Defendants for an extension of time and no parties will be prejudiced by the relief sought in this Motion. 6. On behalf of Brandon Barnes, John Hutto, and the City, Mr. Ratner requests a similar extension and joins in the relief sought in this Motion. 7. The undersigned certifies that the undersigned has served a copy of this Motion on Officer Hopkins. Mr. Ratner certifies that a copy has been served on his clients. Wherefore, the Defendants respectfully request an extension, up to and including March 23, 2020, in which to submit reply briefs in support of ECF 96 and ECF 98. Respectfully submitted this 12th day of March, 2020. s/Nick Poppe Marni Nathan Kloster Nicholas C. Poppe NATHAN DUMM & MAYER P.C. 7900 E. Union Avenue, Suite 600 Denver, CO 80237-2776 Phone Number: (303) 691-3737 Fax: (303) 757-5106 Attorneys for Defendant Todd Hopkins - AND - Case 1:18-cv-03112-RBJ-STV Document 110 Filed 03/12/20 USDC Colorado Page 2 of 4 -3- /s/ Mark S. Ratner Mark S. Ratner Hall & Evans, L.L.C. 1001 17 th Street, Suite 300 Denver, CO 80202 Phone: 303-628-3300 Fax: 303-628-3368 ratnerm@hallevans.com ATTORNEYS FOR DEFENDANTS DEFENDANT BARNES, JOHN HUTTO, AND THE CITY OF FORT COLLINS Case 1:18-cv-03112-RBJ-STV Document 110 Filed 03/12/20 USDC Colorado Page 3 of 4 -4- CERTIFICATE OF SERVICE I hereby certify that on this 12th day of March, 2020, I electronically filed the foregoing DEFENDANTS’ JOINT UNOPPOSED MOTION FOR EXTENSION OF TIME TO SUBMIT REPLY BRIEFS IN SUPPORT OF THEIR MOTIONS TO DISMISS [ECF 96 & 98] with the MOTION FOR EXTENSION Clerk of Court using the CM/ECF system which will send notification of such filing to the following at their e-mail addresses:. David A. Lane KILLMER, LANE & NEWMAN, LLP dlane@kln-law.com ATTORNEYS FOR PLAINTIFFS Mark Scott Ratner Hall & Evans LLC-Denver ratnerm@hallevans.com ATTORNEY FOR DEFENDANT CITY OF FORT COLLINS, BARNES AND HUTTO S/Nick Poppe Marni Nathan Kloster Nicholas C. Poppe Attorney for Defendants NATHAN DUMM & MAYER P.C. 7900 E. Union Avenue, Suite 600 Denver, CO 80237-2776 Phone Number: (303) 691-3737 Facsimile: (303) 757-5106 MNathan@ndm-law.com Case 1:18-cv-03112-RBJ-STV Document 110 Filed 03/12/20 USDC Colorado Page 4 of 4