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HomeMy WebLinkAbout2017CV1177 - Mcgrath V. Fcps Officer Nick Rogers - 064 - Plaintiff's Unopposed Motion To Substitute City Of Fort Collins As Sole Party DefendantIN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 1:17-cv-01177-LTB-NYW LAURA TYLER, Personal Representative of the Estate of Dakota Tyler McGrath, Plaintiff, v. NICK RODGERS, Fort Collins Police Services Officer, in his individual capacity, Defendant. PLAINTIFF’S UNOPPOSED MOTION TO SUBSTITUTE THE CITY OF FORT COLLINS AS SOLE PARTY DEFENDANT FOR FORT COLLINS POLICE SERVICES OFFICER NICK ROGERS Plaintiff Laura Tyler, as Personal Representative of the Estate of Dakota McGrath (“Ms. Tyler”), by her undersigned attorneys, hereby submits this Unopposed Motion to Substitute the City of Fort Collins as Sole Party Defendant for Fort Collins Police Services Officer Nick Rogers, 1 stating in support as follows: 1. STATEMENT REGARDING CONFERRAL: Undersigned counsel certifies he conferred with counsel for Defendant Fort Collins Police Services Officer Nick Rogers, who does not oppose this Motion. 2. The Parties resolved their differences. 3. Each party will pay its own attorney fees and costs arising in relation to the parties to be determined here. 1 Incorrectly identified in the Complaint as “Nick Rodgers.” Case 1:17-cv-01177-LTB-NYW Document 64 Filed 10/19/18 USDC Colorado Page 1 of 3 2 4. Ms. Tyler requests that the Court strike from all captions in this matter Defendant Fort Collins Police Services Officer Nick Rogers. 5. Ms. Tyler further requests that, pursuant to Fed.R.Civ.P. 25, the Court substitute the City of Fort Collins as the sole remaining party Defendant in this matter. 6. The Parties jointly intend this matter to be fully and finally dismissed upon the filing of the Joint Stipulated Motion to Dismiss with Prejudice, which is being filed contemporaneously with this Unopposed Motion. Respectfully submitted this 19 th day of October, 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 Case 1:17-cv-01177-LTB-NYW Document 64 Filed 10/19/18 USDC Colorado Page 2 of 3 3 CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that, on this 18 th day of October, 2018, I sent a true and correct copy of the foregoing PLAINTIFF’S UNOPPOSED MOTION TO SUBSTITUTE THE CITY OF FORT COLLINS AS SOLE PARTY DEFENDANT FOR FORT COLLINS POLICE SERVICES OFFICER NICK ROGERS through transmission to the following via e-mail: Matthew J. Hegarty, Esq. Thomas J. Lyons, Esq. Hall & Evans, LLC 1001 Seventeenth Street, Suite 300 Denver, CO 80202 Attorneys for Defendant [Original signature on file at Viorst Law Offices, P.C.] s/ Michelle Spadavecchia Legal Assistant Case 1:17-cv-01177-LTB-NYW Document 64 Filed 10/19/18 USDC Colorado Page 3 of 3