HomeMy WebLinkAbout2018CV3112 - Sean Slatton V. Fort Collins Police Department, Todd Hopkins, Brandon Barnes And John Hutto - 146 - Plaintiff's Second Unopposed Motion For Extension Of TimeIN 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.
______________________________________________________________________________
SECOND 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 sixteen (16) days to submit his Response up to and including
November 24, 2021. 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 original deadline for Plaintiff to respond is October 25, 2021.
3. Upon motion by Plaintiff, the Court granted a two-week extension for Plaintiff to
respond. Plaintiff’s Response is currently due on November 8th.
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4. This week, the parties set this matter for mediation. A full day mediation is
currently scheduled for November 10, 2021, with Judicial Arbiter Group (JAG) arbiter Judge
Thomas Moorhead. Counsel for Plaintiff was diligently working to complete the Response;
however, the focus of the case has recently shifted to resolution and preparation for next week’s
mediation.
5. Tyrone Glover, who is the attorney primarily responsible for drafting the
Response, in addition to the usual press of business: is drafting and compiling the mediation
packet currently due, November 8, 2021, the same day as the Response at issue in this Motion
6. David A. Lane, counsel for Plaintiff, is scheduled to be in trial November 15th-
20th on Monisha Bush v. Liberty Global, Inc., 19-cv-03495-DDD-KLM, which has required
considerable time and preparation.
7. 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 (16) days, up to and including November 24, 2021.
Respectfully submitted this 5th day of November 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 November 5, 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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