HomeMy WebLinkAbout2021CV30613 - JOSHUA HOLOWCZENKO v. LISA N. BUTLER, CITY OF FORT COLLINS, and LORI S. MARTIN - 004A - PROPOSED ORDER GRANTING MOTION FOR ENLARGEMENT OF TIME TO FILE RESPONSIVE PLEADINGDISTRICT COURT, LARIMER COUNTY, COLORADO
201 LaPorte Ave., Ste. 100
Fort Collins, CO 80521
(970) 494-3500
COURT USE ONLY
Plaintiff: JOSHUA HOLOWCZENKO
v.
Defendants: LISA N. BUTLER, an individual, CITY OF
FORT COLLINS, a municipal corporation, and LORI S.
MARTIN, an individual
Andrew W. Callahan, #52421 – acallahan@wicklaw.com
WICK & TRAUTWEIN, LLC
323 South College Avenue, Suite 3
Fort Collins, CO 80522
Phone & Fax Number: (970) 482-4011
Case No.: 2021CV30613
Division: 5A
UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE
RESPONSIVE PLEADING
COMES NOW, Defendants, Lisa N. Butler and City of Fort Collins, by and through their
attorneys, Andrew W. Callahan of Wick & Trautwein, LLC and respectfully requests an
enlargement of time within which to file Defendants’ responsive pleading in this matter. As
grounds for same, Defendants state:
Undersigned counsel has conferred in good faith with Plaintiff’s counsel regarding the
relief requested herein. Plaintiff’s counsel does not oppose this motion and has granted Defendants
an enlargement of time within which to file its responsive pleading to September 17, 2021.
WHEREFORE, Defendants Lisa N. Butler and the City of Fort Collins respectfully request
an enlargement of time within which to file their responsive pleading to Plaintiff’s complaint
through and until September 17, 2021.
DATE FILED: September 13, 2021 9:08 AM
FILING ID: F03B48D440137
CASE NUMBER: 2021CV30613
2
Respectfully submitted this 13TH day of September, 2021.
WICK & TRAUTWEIN, LLC
By: s/ Andrew W. Callahan
Andrew W. Callahan, #52421
Attorneys for Defendants
CERTIFICATE OF ELECTRONIC FILING
The undersigned hereby certifies that a true and correct copy of the foregoing UNOPPOSED
MOTION FOR ENLARGEMENT OF TIME TO FILE RESPONSIVE PLEADING was filed with
the Court via Colorado Courts E-filing System (CCES) this 13th day of September, 2021 and served
on the following:
Michael P. Fossenier
Law Office of Michael Fossenier, LLC
4100 E. Mississippi Ave., 19th Floor
Denver, CO 80246
Jeremy Rosenthal
Law Firm of Jeremy Rosenthal
4100 E. Mississippi Ave., 19th Floor
Denver, CO 8 0246
/s/ Jody L. Minch ___