HomeMy WebLinkAbout2023CV30276 - Higgins V. V. City Of Fort Collins, Et Al. - 021 - Motion For EnlargementDISTRICT COURT, LARIMER COUNTY, COLORADO
201 LaPorte Ave., Ste. 100
Fort Collins, CO 80521
(970) 494-3500
COURT USE ONLY
Plaintiff: CHRISTIAN HIGGINS
v.
Defendants: CITY OF FORT COLLINS, C&L WATER
SOLUTIONS, INC., SUNBELT RENTALS, INC.,
KODIAK FIELD SERVICES, LLC, and BCH
SERVICES, LLC
Andrew W. Callahan, #52421 – acallahan@wicklaw.com
WICK & TRAUTWEIN, LLC
323 South College Avenue, Suite 3
Fort Collins, CO 80522
Phone & Fax Number: (970) 482-4011
Case No.: 2023CV30276
Division: 4C
UNOPPOSED MOTION FOR ENLARGEMENT OF
TIME TO FILE RESPONSIVE PLEADING
COMES NOW, Defendant City of Fort Collins (“City”), by and through its attorneys,
Andrew W. Callahan of Wick & Trautwein, LLC and respectfully requests an enlargement of time
within which to file Defendant City’s responsive pleading in this matter. As grounds for same,
Defendant City states:
Undersigned counsel has conferred in good faith with Plaintiff’s counsel regarding the
relief requested herein. Plaintiff’s counsel does not oppose this motion.
Defendant City’s responsive pleading is due on or before May 25, 2023. Defendant is
requesting a brief enlargement of time, through and until June 9, 2023, to file its responsive
pleading in this matter.
WHEREFORE, Defendant City respectfully requests a brief enlargement of time within
which to file its responsive pleading to Plaintiff’s complaint through and until June 9, 2023.
DATE FILED: May 23, 2023 4:06 PM
FILING ID: 6A0C1DC56735D
CASE NUMBER: 2023CV30276
2
Respectfully submitted this 23rd day of May, 2023.
WICK & TRAUTWEIN, LLC
By: s/ Andrew W. Callahan
Andrew W. Callahan, #52421
Attorneys for Defendant City of Fort Collins
CERTIFICATE OF ELECTRONIC FILING
The undersigned hereby certifies that a true and correct copy of the foregoing UNOPPOSED
MOTION FOR ENLARGEMENT OF TIME TO FILE RESPONSIVE PLEADING was filed
with the Court via Colorado Courts E-filing System (CCES) this 23rd day of May, 2023 and served
on the following:
Karl W. Hager
VanMeveren Law Group, P.C.
123 N. College Ave., Ste. 112
Fort Colins, CO 80524
/s/ Jody L. Minch ___