HomeMy WebLinkAbout2022-cv-1983-SKC - Townley V. Fort Collins, Et Al - 055 - Motion Extension File Mot Compel And ResponseIN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No.1:22-cv-01983-SKC
MICHAEL PIPER TOWNLEY,ANNA KRUGER,and JOSHUA DeLEON;
Plaintiffs,
v.
BRIAN MALLORY,in his individual capacity;
ETHAN VANSICKLE,in his individual capacity;
DANIEL NETZEL,in his individual capacity;
JARED ROBERTSON,in his individual capacity;
JOE SCHILZ,in his individual capacity;
JASON HAFERMAN,in his individual capacity;
CHRISTOPHER YOUNG,in his individual capacity.
Defendants.
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE MOTION TO COMPEL
AND RESPONSE
Plaintiffs,by and through undersigned counsel,respectfully move this Court to extend the
deadline for Plaintiffs to submit their Motion to Compel and in support thereof,provide as
follows:
1.On September 7,2023,counsel for Plaintiffs and counsel for Defendants,serving
as Counsel for Third Party City of Fort Collins,conducted a joint discovery call
with this Court’s chambers pursuant to this Court’s Practice Standards.
Case No. 1:22-cv-01983-SKC Document 55 filed 10/06/23 USDC Colorado pg 1 of 3
2.On September 7,2023,Plaintiffs provided an email to explain the discovery
dispute arising from a subpoena served on the City of Fort Collins.
3.On September 15,2023,counsel for the City of Fort Collins provided a response.
4.On September 22,2023,this Court issued a minute order directing Plaintiffs to
file a motion to compel on or before October 6,2023.ECF No.53.
5.City of Fort Collins was to respond within 14 days of such filing.
6.Undersigned counsel conducted a jury trial this week and accordingly,has not
been able to work with the City of Fort Collins to attempt narrow the dispute and
hopefully resolve the issues outlined in Plaintiffs’September 7 email.
7.Undersigned counsel and counsel for City of Fort Collins are discussing efforts to
resolve these issues,but because of undersigned counsel’s trial schedule,the
Parties need an additional week.
8.Accordingly,Plaintiffs make this unopposed motion seeking an additional week in
which to file a motion to compel so that ongoing efforts to address this dispute
may be resolved.
WHEREFORE,Plaintiffs respectfully request that this Court enter an order extending the
deadline to file a Motion to Compel on the outstanding discovery dispute until October 13,2023
so that the Parties may continue to work together to narrow or resolve all outstanding issues.
Respectfully submitted this 6th day of October 2023.
Case No. 1:22-cv-01983-SKC Document 55 filed 10/06/23 USDC Colorado pg 2 of 3
/s/Edward Milo Schwab
Edward Milo Schwab,#47897
Ascend Counsel,LLC
2401 S Downing Street Street
Denver,CO 80210
(303)888-4407
milo@ascendcounsel.co
ATTORNEY FOR PLAINTIFFS
Case No. 1:22-cv-01983-SKC Document 55 filed 10/06/23 USDC Colorado pg 3 of 3