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HomeMy WebLinkAbout2021-cv-2063-CNS-MEH - City Of Fort Collins V. Open International, Et Al. - 024 - Joint Motion For Extension Of Time To File Protective Order IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No.: 21-cv-02063-DDD-NYW CITY OF FORT COLLINS, Plaintiff/Counterclaim Defendant, v. OPEN INTERNATIONAL, LLC Defendant/Counterclaim Plaintiff, and OPEN INVESTMENTS, LLC, Defendant. JOINT MOTION FOR EXTENSION OF TIME TO SUBMIT PROPOSED STIPULATED PROTECTIVE ORDER The Parties, through their respective counsel, hereby jointly and respectfully move this Court for a one-week extension of time, until October 1, 2021, to submit their Proposed Stipulated Protective Order concerning the treatment of Protected Material pursuant to Rule 26(c) of the Federal Rules of Civil Procedure. In support thereof, the Parties state as follows: 1. On September 16, 2021, during the Parties’ Scheduling Conference, the Court ordered the Parties to submit a draft Protective Order by September 24, 2021. [ECF 22]. 2. Consistent with the Court’s directive, the Parties have circulated a draft Protective Order along with their respective edits and comments. The Parties are currently negotiating a few remaining terms. The Parties anticipate that they will be able to complete all necessary discussions and submit a draft Protective Order to the Court by next Friday, October 1, 2021. Case 1:21-cv-02063-DDD-NYW Document 24 Filed 09/24/21 USDC Colorado Page 1 of 3 2 3. Good cause exists for granting the request for an extension. The Parties desire to continue their negotiation of the terms to avoid any unnecessary briefing or waste of judicial resources. The extension requested herein will facilitate the Parties’ ongoing discussions while they continue to collect the necessary documents and information from their respective clients. 4. This motion is made in good faith and not for purposes of delay. The requested extension will not prejudice any party. 5. In accordance with D.C.COLO.LCivR 6.1(c), the undersigned certify that this motion is being served on their respective clients contemporaneously with the filing hereof. WHEREFORE, the Parties respectfully request that this Court issue an Order granting a one week extension of time until October 1, 2021 to submit a draft Protective Order. Respectfully submitted this 24th day of September, 2021. DORSEY & WHITNEY LLP /s/ Maral J. Shoaei HOLLAND & HART LLP /s/ Paul D. Swanson Case Collard Andrea Ahn Wechter Maral J. Shoaei 1400 Wewatta Street, Ste. 400 Denver, Colorado 80202 Telephone: (303) 629-3400 Facsimile: (303) 629-3450 Email: collard.case@dorsey.com wechter.andrea@dorsey.com shoaei.maral@dorsey.com Counsel for Plaintiff Paul D. Swanson Chris D. Mack Hannah E. Armentrout 555 17th Street, Suite 3200 Denver, Colorado 80202 Telephone: (303) 295-8578 Facsimile: (303) 416-8814 Email: pdswanson@hollandhart.com cdmack@hollandhart.com hearmentrout@hollandhart.com Counsel for Defendants Case 1:21-cv-02063-DDD-NYW Document 24 Filed 09/24/21 USDC Colorado Page 2 of 3 3 CERTIFICATE OF SERVICE I hereby certify that on September 24, 2021, I caused the foregoing document, titled JOINT MOTION FOR EXTENSION OF TIME TO SUBMIT PROPOSED STIPULATED PROTECTIVE ORDER, to be filed via the CM/ECF system which will send notification of the availability of such filing to the following: Paul D. Swanson Chris D. Mack Hannah E. Armentrout 555 17th Street, Suite 3200 Denver, Colorado 80202 Telephone: (303) 295-8578 Facsimile: (303) 416-8814 Email: pdswanson@hollandhart.com cdmack@hollandhart.com hearmentrout@hollandhart.com Attorneys for Defendants s/ Cheryl Duff Dorsey & Whitney LLP Case 1:21-cv-02063-DDD-NYW Document 24 Filed 09/24/21 USDC Colorado Page 3 of 3