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HomeMy WebLinkAbout2019CV30889 - Adam Wiemold V. City Of Fort Collins - 015 - Unopposed Motion For 30-Day Extension Of Time To File Appellee's Responsive BriefLARIMER COUNTY DISTRICT COURT 201 LAPORTE AVENUE, SUITE 100 FORT COLLINS, CO 80521 Court Use Only Defendant-Appellant: ADAM WIEMOLD, v. Plaintiff-Appellee: CITY OF FORT COLLINS Jill A. Hueser, #42324 Lead Municipal Prosecutor City Attorney's Office 300 LaPorte Avenue PO Box 580 Fort Collins, Colorado 80522 Appellate Case No: 19CV30889 Municipal Court Case No: 2018-240752-MD Courtroom: 5A UNOPPOSED MOTION FOR 30-DAY EXTENTION OF TIME TO FILE APPELLEE’S RESPONSIVE BRIEF COMES NOW, the City of Fort Collins, by and through the Fort Collins City Attorney’s Office, and requests the Court grant a 30-day extension of time to file the City’s responding brief. The City has conferred with counsel for Mr. Wiemold, and he does not object to the requested extension. As grounds, the City states as follows: 1. The Court previously granted the Appellant an unopposed 30-day extension for his opening brief. 2. The City intends to coordinate with outside counsel on its responsive brief. 3. Mr. Wiemold filed his opening brief on Monday, March 30, 2020, making the current deadline April 20, 2020. The City is requesting an extension until and including May 20, 2020. 4. The City Attorney’s Office has been especially busy lately, transitioning to remote work while addressing legal issues presented by the current COVID-19 emergency. 5. Mr. Wiemold will not be prejudiced by the delay and has no objection to the extension. WHEREFORE, the City requests its responsive brief deadline be extended to and including May 20, 2020. DATED: April 7, 2020 Respectfully submitted, CITY OF FORT COLLINS, COLORADO By: _/s/Jill A. Hueser___________ Jill A. Hueser #42324 Lead Municipal Court Prosecutor CERTIFICATE OF ELECTRONIC FILING The undersigned hereby certifies that a true and correct copy of the foregoing UNOPPOSED MOTION FOR 30-DAY EXTENTION OF TIME TO FILE APPELLEE’S RESPONSIVE BRIEF was filed via the Colorado Courts E-Filing System and served this 7th day of April, 2020, on the following: Adam Frank, #38979 FRANK & SALAHUDDIN LLC 1741 High Street Denver, CO 80218 Phone: (303) 974-1084 Fax: (303) 974-1085 E-mail: adam@fas-law.com In cooperation with the American Civil Liberties Union Foundation of Colorado Mark Silverstein, #26979 Rebecca Wallace, #39606 ACLU Foundation of Colorado 303 E. 17th Ave., Suite 350 Denver, CO 80203 Phone: (303) 777-5482 Fax: (303) 777-1773 Email: msilverstein@aclu-co.org rtwallace@aclu-co.org s/ Cary J. Carricato [The original certificate of electronic filing signed by Cary J. Carricato is on file at the Fort Collins City Attorney’s Office)