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HomeMy WebLinkAbout2020CV30833 - CITY OF FORT COLLINS V. PLANNING ACTION TO TRANSFORM HUGHES STADIUM SUSTAINABLY CORP, ET. AL - 009 - WAIVER OF SERVICE OF SUMMONS AND COMPLAINTDISTRICT COURT, COUNTY OF LARIMER, COLORADO Larimer County Justice Center 201 Laporte Avenue, Suite 100 Fort Collins, Colorado 80521-2762 (970) 498-6100 ______________________________________________ Plaintiff: THE CITY OF FORT COLLINS, COLORADO, a Colorado home rule city and municipal corporation, v. Defendants: PLANNING ACTION TO TRANSFORM HUGHES STADIUM SUSTAINABLY CORP, a Colorado nonprofit corporation; and ELENA M. LOPEZ, MELISSA ROSAS, AND PAUL PATTERSON, each in their official capacity as a petition representative of the persons signing the petition for a citizen-initiated ordinance relating to the City of Fort Collins rezoning and acquiring certain real property ______________________________________________ Carrie M. Daggett #23316 - City Attorney John R. Duval #10185 - Deputy City Attorney Fort Collins City Attorney’s Office 300 Laporte Avenue P.O. Box 500 Fort Collins, Colorado 80522 970-221-6520 cdaggett@fcgov.com , jduval@fcgov.com Andrew D. Ringel #24762 Hall & Evans, L.L.C. 1001 17th Street, Suite 300 Denver, CO 80202 303-628-3300 Fax: 303-628-3368 ringela@hallevans.com Attorneys for Plaintiff ▲COURT USE ONLY ▲ _________________________ Case Number: 2020CV30833 Division: ___ WAIVER OF SERVICE OF SUMMONS AND COMPLAINT DATE FILED: December 8, 2020 9:49 AM FILING ID: 798AE2DF1A278 CASE NUMBER: 2020CV30833 2 I, Michael Foote, Esq., on behalf of Defendants Planning Action to Transform Hughes Stadium Sustainably Corp, Elena M. Lopez, Melissa Rosas, and Paul Patterson hereby acknowledge receipt of the following items via electronic mail on December 7, 2020: 1. Complaint for Review Pursuant to C.R.C.P. 57 and the Uniform Declaratory Judgment Law with Exhibits A-L; 2. Civil Cover Sheet; 3. District Court Civil Summonses for each Defendant; 4. Motion for Expedited Consideration and proposed Order. I hereby agree to waive personal service of the Summons and Complaint pursuant to C.R.C.P. 4(e) and instead waive service pursuant to C.R.C.P. 4(i). I understand no waiver of any objection other than an objection to service of process occurs based on this waiver. I also understand the Defendants are required to respond to the Complaint for Review Pursuant to C.R.C.P. 57 within 21 days of the date this Waiver is executed and is required to respond to the Motion for Expedited Consideration within 21 days of the date this Waiver is executed, although I also acknowledge and understand the District Court may rule on the Motion prior to this time. Dated this 8th day of December, 2020. Michael Foote, Esq.