HomeMy WebLinkAbout2019-cv-901 - Surat v. City of Fort Collins, et al. - 122 - JOINT MOTION TO STAY PRETRIAL ORDER DEADLINE UNTIL RULING ON PENDING MOTIONSIN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 19 -cv-00901-NRN
MICHAELLA LYNN SURAT,
Plaintiff,
v.
RANDALL KLAMSER, in his individual capacity, and
CITY OF FORT COLLINS, a municipality,
Defendants.
JOINT MOTION TO STAY PRETRIAL ORDER DEADLINE UNTIL
AFTER A RULING ON THE PENDING MOTIONS
Plaintiff and Defendants, through undersigned counsel, file their Joint Motion to Stay
Pretrial Order Deadline Until After a Ruling on the Pending Motions, and as grounds therefore,
state as follows:
1. On October 19, 2020, Plaintiff filed an unopposed motion for leave to file a
consolidated response to Defendants’ motion to dismiss and motion for summary judgment, and
a motion for extension up to and including November 24, 2020 to file the consolidated response.
[Doc. 120].
3. The pretrial order is currently due on November 11, 2020.
4. In the interest of judicial economy and efficiency for the Parties, the Parties
request a stay on the pretrial order for a date to be set by this Court after a ruling has been made
on the pending motion to dismiss and motion for summary judgment.
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WHEREFORE, the Parties respectfully request that the Court enter the attached Joint
Motion to Stay Pretrial Order Deadline Until After a Ruling on the Pending Motions.
CERTIFICATION PURSUANT TO D.C.COLO. LCIVR. 6.1(C)
5. Counsel for Plaintiff and Defendant certify that this motion will be served
contemporaneously on their clients upon the filing of this motion.
Respectfully submitted this 20th day of October, 2020.
_s/ Helen Oh
David Lane
Helen Oh
Andy McNulty
KILLMER, LANE & NEWMAN, LLP
1543 Champa Street, Suite 400
Denver, CO 80202
(303) 571-1000
(303) 571-1001 fax
dlane@kln-law.com
hoh@kln-law.com
amcnulty@kln-law.com
Counsel for Plaintiff
s/Mark Ratner
Mark Ratner
Brenden Desmond
Hall & Evans, LLC
1001 Seventeenth Street, Ste 300
Denver, CO 80202
303-628-3492
ratnerm@hallevans.com
desmondb@hallevans.com
s/John Duval__
John R. Duval, Esq.
Deputy City Attorney
City of Fort Collins
P.O. Box 580
Fort Collins, CO 80522
(970) 221-6520
jduval@fcgov.com
Counsel for Defendants
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CERTIFICATE OF SERVICE
I certify that pursuant to Section II.D.2.b. of Hon. William J. Martinez’s Practice Standards a
true and correct copy of the above and foregoing was contemporaneously served via email on
Plaintiff Michaella Surat.
s/ Jamie Akard
Jamie Akard
I certify that pursuant to Section II.D.2.b. of Hon. William J. Martinez’s Practice Standards a
true and correct copy of the above and foregoing was contemporaneously served via email on
Defendants Randall Klamser and Representative of Fort Collins.
s/ Mark Ratner
Mark Ratner
s/ John Duval__
John Duval
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