Loading...
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 Case No. 1:19-cv-00901-WJM-NRN Document 194 filed 08/09/23 USDC Colorado pg 1 of 3 2 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 Case No. 1:19-cv-00901-WJM-NRN Document 194 filed 08/09/23 USDC Colorado pg 2 of 3 3 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 Case No. 1:19-cv-00901-WJM-NRN Document 194 filed 08/09/23 USDC Colorado pg 3 of 3