HomeMy WebLinkAbout2022-cv-1983-SKC - Townley V. Fort Collins, Et Al - 013 - City, Mallory, Vansickle, Robertson, Young Motion For ExtensionIN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 1:22-CV-01983-SKC
MICHAEL PIPER TOWNLEY, ANNA KRUGER, and JOSHUA DeLEON;
Plaintiff,
v.
FORT COLLINS, a municipal entity;
BRIAN MALLORY, in his individual capacity;
ETHAN VanSICKLE, in his individual capacity;
DANIEL NETZLE, in his individual capacity;
JARED ROBERTSON, in his individual capacity;
JOE SCHILZ, in his individual capacity;
JASON HAFERMAN, in his individual capacity;
CHRISTOPHER YOUNG, in his individual capacity;
JOHN DOES 1-100, in their individual capacities.
Defendant.
DEFENDANTS CITY OF FORT COLLINS, BRIAN MALLORY, ETHAN VAN SICKLE,
JARED ROBERTSON AND CHRISTOPHER YOUNG’S UNOPPOSED MOTION FOR
EXTENSION OF TIME
Defendants the City of Fort Collins, Brian Mallory, Ethan VanSickle, Jared
Robertson, and Christopher Young, by and through their undersigned counsel, Hall &
Evans, LLC, submit the following as their Unopposed Motion for Extension of Time.
CERTIFICATE OF CONFERRAL
Undersigned Counsel conferred with Counsel for Plaintiffs regarding the relief
requested in this Motion. Counsel for the Plaintiffs indicated there is no objection.
Therefore, this Motion is unopposed.
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I. ARGUMENT
According to the allegations of Plaintiffs’ Complaint, this matter arises out of a
protest which took place in the City of Fort Collins, Colorado, on August 8, 2020 (ECF 1,
at ¶15).
On September 1, 2022, Defendants the City of Fort Collins, and Fort Collins Police
Officers Mallory, Robertson, Van Sickle, and Young, filed Waivers of Service. (See ECF
6-10). These Waivers were dated August 23, 2022, and pursuant to the applicable Rules,
responses to Plaintiffs’ Complaint from these Defendants, are due on October 22, 2022
(ECF 6-10).
On October 18, 2022, Defendants Haferman and Schilz filed Waivers of Service,
which were dated September 8, 2022 (See ECF 11 & 12). According to the applicable
Rules, responses to Plaintiffs’ Complaint from Haferman and Schilz, are due by
November 7, 2022.
Plaintiffs’ Complaint consists of 261 paragraphs and 18 claims, against multiple
Defendants. Furthermore, as a result of submitting Waivers of Service which were
executed on different dates, multiple responses are due at different times. In order to
provide some consistency, Defendants, the City of Fort Collins, Brian Mallory, Ethan
VanSickle, Jared Robertson, and Christopher Young, request their responses to Plaintiffs’
Complaint be due on the same day as Defendants Haferman and Schilz-November 7,
2022.
WHEREFORE, Defendants, the City of Fort Collins, Brian Mallory, Ethan
VanSickle, Jared Robertson, and Christopher Young, respectfully request the Court grant
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their Motion, and Order a response on behalf of these Defendants be filed on or before
November 7, 2022.
Respectfully submitted this 18th day of October 2022.
s/ Mark S. Ratner
Mark S. Ratner, Esq.
Andrew D. Ringel, Esq.
Hall & Evans, L.L.C.
1001 17th Street, Suite 300, Denver, CO 80202
303-628-3300 /Fax: 303-628-3368
ratnerm@hallevans.com
ringela@hallevans.com
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CERTIFICATE OF SERVICE (CM/ECF)
I hereby certify that on the 18th day of October 2022, a true and correct copy of
the foregoing DEFENDANTS CITY OF FORT COLLINS, BRIAN MALLORY, ETHAN
VAN SICKLE, JARED ROBERTSON AND CHRISTOPHER YOUNG’S UNOPPOSED
MOTION FOR EXTENSION OF TIME was filed with the Court via CM/ECF and served
on the below-listed party by email:
Edward Milo Schwab, Esq.
milo@ascendcounsel.co
s/ Sarah Stefanick
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