HomeMy WebLinkAbout2019-cv-901 - Surat V. City Of Fort Collins, Et Al. - 194 - Unopp Mot To Vacate And Reset TrialIN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 19-cv-00901-WJM-NRN
MICHAELLA LYNN SURAT,
Plaintiff,
v.
RANDALL KLAMSER, in his individual capacity, and
CITY OF FORT COLLINS, a municipality,
Defendants.
UNOPPOSED MOTION TO
VACATE AND RESET TRIAL
Plaintiffs, by and through their counsel, David Lane and Andrew McNulty of KILLMER
LANE & NEWMAN, LLP, hereby submits the following Unopposed Motion to Vacate and Reset
Trial, and in support thereof states:
1. In accordance with D.C.COLO.LCivR 7.1(a), undersigned counsel certifies that
he conferred with Defendant’s Counsel, Mark Ratner, regarding this motion. Mr. Ratner advised
that his client does not oppose this request.
2. The trial in this matter has been set to begin on March 18, 2024 and the Final
Trial Prep Conference is set for March 1, 2024 [Doc. 189].
3. Lead counsel for Plaintiff, David A. Lane has discovered that this setting conflicts
with his grandchildren’s spring break. The family would like to travel together out of the country
for spring break, during the week this case is currently set for trial.
4. Plaintiff respectfully requests that the Trial and Trial Preparation Conference be
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reset to a time as soon as possible when the Court and all parties are available after the current
March 18, 2024 trial date.
5. Ms. Surat does not object to this re-setting.
6. This request will not prejudice any party and is not made for the purposes of
delay.
7. In accordance with D.C.COLO.LCivR. 6.1 (c), undersigned counsel certifies that
this motion will be served contemporaneously on his client upon filing of the motion.
Respectfully submitted this 9th day of August 2023.
KILLMER, LANE & NEWMAN, LLP
s/ David A. Lane
David A. Lane
Andrew McNulty
Killmer, Lane & Newman, LLP
1543 Champa St., Ste. 400
Denver, CO 80202
Telephone: (303) 571-1000
Facsimile: (303) 571-1001
dlane@kln-law.com
amcnulty@kln-law.com
Attorneys for Plaintiffs
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CERTIFICATE OF SERVICE
The undersigned hereby certifies that on the 9th day of August, 2023, a true and correct
copy of the foregoing MOTION TO VACATE AND TRIAL AND PRETRIAL
CONFERENCE was filed with the Clerk of Court using the CM/ECF system, which will send
notification of such filing to the following email address:
Mark Ratner
Hall & Evans, LLC
1001 Seventeenth Street, Ste 300
Denver, CO 80202
303-628-3492
ratnerm@hallevans.com
s/ Jamie Akard
Paralegal
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