HomeMy WebLinkAbout2021CV30429 - JAMES M. BELL-AVERA V. KARL L. ROHR and THE CITY OF FORT COLLINS - 009 - MOTION FOR ENLARGMENT 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: JAMES M. BELL-AVERA
v.
Defendant: KARL L. ROHR and THE CITY OF FORT
COLLINS
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.: 2021CV30429
Division: 3C
UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE
RESPONSIVE PLEADING
COMES NOW, Defendants, by and through its 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 24, 2021.
WHEREFORE, Defendants respectfully request an enlargement of time within which to
file its responsive pleading to Plaintiff’s complaint through and until September 24, 2021.
Respectfully submitted this 26th day of August, 2021.
DATE FILED: August 26, 2021 11:36 AM
FILING ID: 8BD7C1ABA98B2
CASE NUMBER: 2021CV30429
2
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 26th day of August, 2021 and served on
the following:
Theodore Ridder
Franklin D. Azar & Associates, P.C.
14426 East Evans Avenue
Aurora, CO 80014
/s/ Jody L. Minch ___