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HomeMy WebLinkAbout2020CV30363 - Stuward Cross And Katrina Richman V. City Of Fort Collins - 057 - Pls' Mot Extension Of Time Reply To MilDISTRICT COURT, LARIMER COUNTY, STATE OF COLORADO Court Address: 201 Laporte Ave. Fort Collins, CO 80621 Plaintiffs: STUWARD CROSS AND KATRINA RICHMAN v. Defendant: THE CITY OF FORT COLLINS, STATE OF COLORADO Court Use Only Attorneys for Plaintiffs: Laura Browne, # 46673 Ashley Fridovich, # 47538 WILHITE, ROSE, MCCLURE &, SAWAYA P.C. 1600 Ogden Street Denver, CO 80218 Phone Number: (303) 839-1650 FAX Number: (303) 832-7102 E-mail: lbrowne@sawayalaw.com afridovich@sawayalaw.com Case Number: 2020CV30363 Division: 3C PLAINTIFFS’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLIES AND RESPONSES TO MOTIONS IN LIMINIE COME NOW, Plaintiffs Stuward Cross and Katrina Richman, by and through their attorneys of record, Wilhite, Rose, McClure, and Sawaya, P.C., and hereby submits their Unopposed Motion for Extension of Time to File their Replies and Responses to Motions in Limine, states the following: C.R.C.P. 121 CONFERRAL Counsel for Plaintiffs conferred with counsel for Defendant, who does not oppose this Motion. BACKGROUND 1. Plaintiffs filed their Complaint on May 29, 2020. 2. A five-day jury trial is set to begin November 15, 2021. DATE FILED: October 26, 2021 2:59 PM FILING ID: 3E37DCBED9076 CASE NUMBER: 2020CV30363 2 3. The deadline for Plaintiffs to file their Replies and Responses to the Motions in Limine is October 25, 2021. 4. Plaintiffs request a one-week extension of time to file these motions. 5. The Defendant does not oppose this Motion. 6. No party will be prejudiced by the one-week extension of time to file the replies and responses to the Motions in Limine. 7. The requested extension of time will not affect the parties’ ability to prepare for trial. CONCLUSION WHEREFORE, Plaintiff respectfully requests this Court GRANT Plaintiff’s Unopposed Motion for Extension of Time to File Replies and Reponses to Motions in Limine through November 1, 2021. DATED: October 26, 2021. Respectfully submitted, WILHITE, ROSE, MCCLURE & SAWAYA, P.C. /s/ Ashley Fridovich Original Signature on File in Attorney’s Office Ashley Fridovich, Attorney for Plaintiff 3 CERTIFICATE OF SERVICE I hereby certify that on October 26, 2021 this PLAINTIFF’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO REPLIES AND RESPONSES TO MOTIONS IN LIMINIE was filed and served via CCEF addressed to the following counsel of record: Andrew W. Callahan, Esq. Julie M. Yates, Esq. WICK & TRAUTWEIN, LLC P.O. Box 2166 Fort Collins, CO 80522 Attorney for Defendant Adam Stephens, Esq. John R. Duval, Esq. FORT COLLINS CITY ATTORNEY’S OFFICE P.O. Box 580 Fort Collins, CO 80522 Attorney for Defendant /s/ Kassandra Burival Original Signature on File in Attorney’s Office Kassandra Burival, Litigation Paralegal