HomeMy WebLinkAbout2018CV3112 - Sean Slatton V. Fort Collins Police Department, Todd Hopkins, Brandon Barnes And John Hutto - 141 - Unopposed Motion For Extension Of Time To File Response1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 1:18-cv-03112-RBJ-STV
SEAN SLATTON,
Plaintiff,
v.
CITY OF FORT COLLINS, a municipality,
Defendants.
______________________________________________________________________________
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO
DEFENDANT’S MOTION FOR SUMMARY JUDGMENT [DOC. 137]
______________________________________________________________________________
Plaintiff, Sean Slatton, by and through undersigned counsel, submits the following
Unopposed Motion for Extension of Time to File his Response to Defendant’s Motion for
Summary Judgment Pursuant to Fed. R. Civ. P. 56 on Behalf of the City of Fort Collins [Doc.
137] and requests an additional fourteen (14) days to submit his Response. In support thereof,
Plaintiff states:
CERTIFICATE OF CONFERRAL
Pursuant to D.C.COLO.LCivR 7.1, counsel for Plaintiff certifies that they conferred via
email with Mark Ratner, Counsel for Defendant, who indicated that his client does not object to
the relief requested herein.
1. On October 4, 2021, the City of Fort Collins filed its Motion for Summary
Judgment [Doc. 137].
2. The current deadline for Plaintiff to respond is October 25, 2021.
3. Counsel for Plaintiff is diligently working to complete the Response; however, an
additional fourteen (14) days, up to and including November 8, 2021, is needed to finalize.
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4. Tyrone Glover, who is the attorney primarily responsible for drafting the
Response, in addition to the usual press of business: was preparing for trial in Manoukian v.
Ouelette 20CV30007 in Boulder District Court which recently settled but was scheduled for
October 11th- 15th, 2021 and is working on responses to three separate motions for summary
judgment in Andersen v. Colorado Springs et. al. 20CV02032-RBJ, which were served on
October 12, 2021.
5. David A. Lane, counsel for Plaintiff, is currently in trial October 18th-22nd on
Castille v. Gann Jr. 17cv00912-RM-SKC, which has required considerable time and preparation.
6. No party will be prejudiced by the relief requested herein.
WHEREFORE, for the foregoing reasons, Plaintiff respectfully requests that this Court
grant this motion for extension of time to file his Response to Defendant’s Motion for Summary
Judgment of an additional fourteen (14) days, up to and including November 8, 2021.
Respectfully submitted this 18th day of October 2021.
s/Tyrone Glover
David A. Lane
Tyrone Glover
KILLMER, LANE & NEWMAN, LLP
1543 Champa Street, Suite 400
Denver, CO 80202
(303) 571-1000
(303) 571-1001 facsimile
dlane@kln-law.com
tglover@kln-law.com
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CERTIFICATE OF SERVICE
I hereby certify that on October 18, 2021, I filed the foregoing via the CM/ECF system,
which will send notice to the following:
Mark Ratner
Hall & Evans, LLC
1001 17th Street, Ste 300
Denver, CO 80202
303-628-3300
ratnerm@hallevans.com
Counsel for Defendant the City of Fort Collins
Sean Slatton
Via email
s/ Tyrone Glover
Attorney
KILLMER, LANE & NEWMAN, LLP
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