HomeMy WebLinkAbout2023-cv-1339 - Groves V. V. City Of Fort Collins, Et Al. - 045 - Pl's Unopp Mot Extension Resp Mtd 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 23-cv-1339-RM-STV
DERRICK GROVES,
Plaintiff,
v.
CITY OF FORT COLLINS,
JASON HAFERMAN,
SERGEANT ALLEN HEATON, and
JASON BOGOSIAN,
Defendants.
PLAINTIFF’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE
RESPONSE TO DEFENDANT’S MOTION TO DISMISS (ECF 42)
Plaintiff Derrick Groves, by and through his attorney, file this Unopposed Motion
for Extension of Time to File Response to Defendant’s Motion to Dismiss and in support
of the same respectfully states as follows:
CERTIFICATE OF CONFERRAL
Sarah Schielke, undersigned counsel for Plaintiff Derrick Groves, contacted
counsel for Defendants, via email on Thursday, November 9 regarding the relief
requested herein. Defendants responded and are unopposed to this Motion.
1. The current deadline for Plaintiff’s response to Defendants’ Motion to Dismiss [ECF
42] is Tuesday November 21.
2. Undersigned counsel’s family fell ill and tested positive for COVID last week. At first
counsel was testing negative. However, counsel began feeling symptoms herself and
Case No. 1:23-cv-01339-RM-STV Document 45 filed 11/16/23 USDC Colorado pg 1 of 3
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tested positive for COVID this week. As of this morning (Thursday) counsel is very
sick with a fever, fatigue, and cough.
3. There are Motions to Dismiss pending in the four related cases (See Notice of Related
Cases, ECF 2) which Plaintiff’s counsel has obtained extensions on the MTD
Response filing deadline for the reason explained above through Monday, November
27, 2023.
4. Wherefore, Plaintiff requests a one-week extension to file his response to the Motion
to Dismiss.
5. No party will be prejudiced by the relief sought herein.
WHEREFORE the Plaintiff respectfully requests a one-week extension to the deadline
for filing Plaintiff’s Response to Defendant’s Motion to Dismiss (ECF 42), to November
27, 2023.
Respectfully submitted this 16th day of November, 2023.
THE LIFE & LIBERTY LAW OFFICE
/s/ Sarah Schielke
Sarah Schielke
The Life & Liberty Law Office LLC
1209 Cleveland Avenue
Loveland, CO 80537
P: (970) 493-1980
F: (970) 797-4008
E: sarah@lifeandlibertylaw.com
Counsel for Plaintiff
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CERTIFICATE OF SERVICE
This is to certify that on November 16, 2023, a true and accurate copy of the foregoing
Motion has been sent to the following parties by PACER/ECF:
Mark Ratner
Robert Weiner
Katherine Hoffman
Hall & Evans, LLC
Attorney for Defendants City of Fort Collins,
Allen Heaton and Jason Bogosian
Yulia Nikolaevskya
Jonathan Abramson
Kissinger & Fellman, P.C.
Attorney for Defendant Jason Haferman
Derrick Groves
Plaintiff /s/ Sarah Schielke
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