HomeMy WebLinkAbout2021-cv-2306-RM-KLM - Perry V. State Of Colorado, Et Al - 023 - Stipulation Of Extension Of Time To Respond To ComplaintIN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 1:21-CV-02306-KLM
ROBERT LAWRENCE PERRY,
Plaintiff,
v.
THE STATE OF COLORADO,
THE CITY OF FORT COLLINS,
CSU BOARD OF GOVERNORS FOR CSU,
COLORADO STATE UNIVERSITY and
STEVEN VASCONSELLOS, Judicial Administrator;
Defendants.
STIPULATION OF EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S
COMPLAINT [ECF 1]
The City of Fort Collins (“Defendant”), by and through counsel, Hall & Evans, LLC,
hereby submits this notice that pursuant to D.C.COLO.L.CivR 6.1(a), the parties, Plaintiff Robert
Perry and Defendant, have stipulated to an extension of time of 21-days for the Defendant to
respond to Plaintiff’s Complaint [ECF 1].
Based on the executed summons, the City’s response to Plaintiff’s Complaint is due on
September 17, 2021. [ECF 17]. With the stipulation of the parties, the City’s response is now due
on or before October 8, 2021.
As reason therefore, undersigned counsel needs additional time to prepare a responsive
pleading and confer with her client. Significantly, Defendant is confronted with a voluminous, 42-
page, 159-paragraph Complaint. Plaintiff’s Complaint raises complex issues under the Fourth,
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Fifth, Eighth, and Fourteenth Amendments as well as other issues requiring separate review and
analysis. Moreover, Plaintiff has notified the parties that he intends to file an amended complaint
regarding these claims and needs time to do so.
No prior extensions have been granted with respect to the Defendant’s response to
Plaintiff’s Complaint or for any other reason.1 No party will be prejudiced by this stipulated
extension.
Pursuant to D.C.COLO.LCivR 6.1(c), a copy of this stipulation has been
contemporaneously served on Defendants.
Dated this 17th day of September, 2021.
s/ Mark S. Ratner
Katherine N. Hoffman, Esq.
Mark S, Ratner, Esq.
Hall & Evans, L.L.C.
1001 17th Street, Suite 300
Denver, CO 80202
Phone: 303-628-3300
Fax: 303-628-3368
ATTORNEYS FOR DEFENDANT
THE CITY OF FORT COLLINS
1 Defendant previously filed an Opposed Motion for 30-day Extension of Time to File
Responsive Pleadings to Plaintiff’s Complaint. [ECF 13]. The Court never ruled on Defendant’s
Opposed Motion. See Docket generally. In a subsequent conferral with Plaintiff on September
16, 2021, Plaintiff notified Defendant he no longer objected to Defendant’s request for an
extension. In light of the parties’ stipulation to extension of time, Defendant’s previously filed
Opposed Motion is moot.
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CERTIFICATE OF SERVICE (CM/ECF)
I HEREBY CERTIFY that on the 17th day of September 2021, I electronically filed the
foregoing with the Clerk of Court using the CM/ECF system which will send notification of such
filing to the following e-mail addresses:
Skippere Stewart Spear, Esq.
Colorado Attorney General’s Office
Skip.spear@coag.gov
Allison R. Ailer, Esq.
Colorado Attorney General’s Office
Allison.ailer@coag.gov
and hereby certify that I have emailed the document to the following non-CM/ECF participant:
Robert Lawrence Perry
fort_scout@yahoo.com
Pro se Plaintiff
s/Sarah Stefanick, Legal Assistant to
Mark S. Ratner, Esq.
Hall & Evans, L.L.C.
1001 17th Street, Suite 300
Denver, CO 80202
Phone: 303-628-3300
Fax: 303-628-3368
Hoffmank@hallevans.com
ATTORNEYS FOR DEFENDANT
THE CITY OF FORT COLLINS
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