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HomeMy WebLinkAbout2023CV30130 - City Of Fort Collins V. Directional Plus, Et Al. - 021 - City's Motion To Modify CmoDISTRICT COURT, LARIMER COUNTY, COLORADO 201 LaPorte Ave., Ste. 100 Fort Collins, CO 80521 (970) 494-3500  COURT USE ONLY  Plaintiff: CITY OF FORT COLLINS v. Defendants: DIRECTIONAL PLUS, LLC, and MASTEC NORTH AMERICA, INC. Andrew W. Callahan, #52421 – acallahan@wicklaw.com WICK & TRAUTWEIN, LLC 323 South College Avenue, Suite 3 Fort Collins, CO 80524 Phone & Fax Number: (970) 482-4011 Case No.: 2023 CV 30130 Division: 3B UNOPPOSED MOTION TO MODIFY THE PRETRIAL DEADLINES IN THE CASE MANAGEMENT ORDER Plaintiff City of Fort Collins, by and through undersigned counsel, Wick & Trautwein, LLC, respectfully submits its Unopposed Motion to Modify the Pretrial Deadlines currently set in the Case Management Order. As grounds for same, Plaintiff states as follows: Rule 121 Certification: Undersigned counsel has conferred with counsel for Directional Plus and Mastec North American regarding the relief requested herein. Counsel consent to the requested extension of time. 1. The parties have experienced a delay in scheduling depositions and respectfully request that the deadlines outlined in the Case Management Order be extended by 30 days to allow for the scheduling of requested depositions. 2. The Case Management Order entered by the court on May 17, 2023 contains the following deadlines in Paragraph 13 pertaining to expert disclosures: DATE FILED: August 29, 2023 2:55 PM FILING ID: FFEF52A5FB394 CASE NUMBER: 2023CV30130 Plaintiff: September 8, 2023 Defendants: October 13, 2023 Rebuttal Reports: November 3, 2023 3. The Case Management Order also contains the following pretrial deadlines: ADR Deadline: October 31, 2023 Discovery Cut Off: December 4, 2023 Deadline to file Notice to Set Trial: December 6, 2023 4. The parties request these deadlines be extended by 30 days and that the Case Management Order be modified to reflect the following new deadlines: Plaintiff’s Expert Disclosures: October 9, 2023 Defendant’s Expert Disclosures: November 13, 2023 Rebuttal Expert Disclosures: December 4, 2023 ADR Deadline: December 1, 2023 Discovery Cut Off: January 3, 2024 Deadline to file Notice to Set Trial: January 5, 2024 WHEREFORE, Plaintiff respectfully requests the foregoing modifications to the Case Management Order to reflect the new deadlines stated herein. Respectfully submitted this 29th day of August, 2023. WICK & TRAUTWEIN, LLC By: s/ Andrew W. Callahan Andrew W. Callahan, #52421 Attorney for Plaintiff CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing UNOPPOSED MOTION TO MODIFY THE PRETRIAL DEADLINES IN THE CASE MANAGEMENT ORDER was filed with the court via CES this 29th day of August, 2023, and served on all counsel of record. s/ Jody L. Minch Paralegal