HomeMy WebLinkAbout2018CV3112 - Sean Slatton V. Fort Collins Police Department, Todd Hopkins, Brandon Barnes And John Hutto - 125 - Defendants' Motion For Extension Of Time To Respond To DiscoveryIN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 18-cv-03112-RBJ-STV
SEAN SLATTON,
Plaintiff
v.
CITY OF FORT COLLINS, A MUNICIPALITY,
Defendant.
_____________________________________________________________________
DEFENDANTS’ UNOPPOSED MOTION FOR EXTENSION OF TIME
TO RESPOND TO PLAINTIFF’S FIRST SET OF WRITTEN DISCOVERY
______________________________________________________________________
Defendant CITY OF FORT COLLINS, a municipality, by and through their attorneys,
Mark S. Ratner of Hall & Evans, L.L.C, submits the following as Defendant’s Unopposed Motion
for Extension of Time to Respond to Plaintiff’s First Set of Written Discovery:
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 Plaintiff. Counsel for Plaintiff does not oppose the relief sought in this Motion.
I. ARGUMENT
1. According to the allegations of Plaintiff’s Complaint, this matter generally arises
out of the arrest of Plaintiff, Sean Slatton, by police officers employed with the City of Fort Collins.
Plaintiff alleges a violation of his Fourth Amendment rights, including the purported use of
excessive force to effectuate his arrest.
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2. On January 21, 2021, Plaintiff served his First Set of Written Discovery on the City
of Fort Collins. Responses to the written discovery are due on or before February 22, 2021.
3. Undersigned Counsel is in the process of drafting appropriate responses, but
requires additional time due to the breadth of the requested information.
4. Defendant is, therefore, requesting an additional 21-days which would make
responses due on or before March 15, 2021.
5. Discovery in this matter concludes on August 10, 2021, and trial is set to begin on
January 10, 2022 (ECF 122). A brief 21-day extension of time is not expected to interfere with
these or any other dates provided in the scheduling order.
6. This is the first request for an extension of time made by Defendant and related to
Plaintiff’s First Set of Discovery.
WHEREFORE, Defendant respectfully requests the Court grant its Motion, and extend the
time to submit responses to Plaintiff’s First Set of Written Discovery, to March 15, 2021.
Dated this 18th day of February, 2021.
Respectfully submitted,
s/ Mark S. Ratner
Mark S. Ratner, Esq.
Hall & Evans, L.L.C.
1001 17th Street, Suite 300, Denver, CO 80202
303-628-3300 /Fax: 303-628-3368
ratnerm@hallevans.com
ATTORNEYS FOR DEFENDANT
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CERTIFICATE OF SERVICE (CM/ECF)
I HEREBY CERTIFY that on the 18th day of February, 2021, I electronically filed the
foregoing DEFENDANTS’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO
RESPOND TO PLAINTIFF’S FIRST SET OF WRITTEN DISCOVERY with the Clerk of
Court using the CM/ECF system and mailed a copy to the following:
David A. Lane, Esq.
Hellen Oh, Esq.
Killmer, Lane & Newman, LLP
1543 Champa Street, Suite 400
Denver, CO 80202
Phone: (303) 571-1000
Facsimile: (303) 571-1001
dlane@kln-law.com
hoh@kln-law.com
ATTORNEYS FOR PLAINTIFF
s/ Sarah Stefanick, Legal Assistant
Hall & Evans, L.L.C.
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