HomeMy WebLinkAbout2021-cv-2063-CNS-MEH - City Of Fort Collins V. Open International, Et Al. - 027 - Joint Motion For Extension To Submit 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 an extension of time, until October 6, 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 worked diligently to negotiate
the Protective Order. The Parties sought a first extension from September 24, 2021 to October 1,
2021. [ECF 24]. The Court granted the extension. [ECF 25].
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3. The Parties have continued discussions and are still working to agree to a
stipulated order but are still negotiating some remaining terms.
4. Good cause exists for granting the request for another 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.
5. This motion is made in good faith and not for purposes of delay. The requested
extension will not prejudice any party.
6. 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 6, 2021 to submit a draft Protective Order.
Respectfully submitted this 1st day of October, 2021.
DORSEY & WHITNEY LLP
/s/ Case Collard
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
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CERTIFICATE OF SERVICE
I hereby certify that on October 1, 2021, I caused the foregoing document, titled JOINT
MOTION FOR EXTENSION OF TIME TO SUBMIT PROPOSED STIPULATED
PROTECTIVE ORDER, to be electronically served via CM/ECF system which will send
notification 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
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