HomeMy WebLinkAbout2023-cv-1339 - Groves V. V. City Of Fort Collins, Et Al. - 047 - 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 TWO-DAY EXTENSION TO FILE
RESPONSE TO DEFENDANT’S MOTION TO DISMISS (ECF 42)
Plaintiff Derrick Groves, by and through his attorney, files this Unopposed Motion
for Two-Day Extension 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 and is authorized to state they are unopposed.
1. The current deadline for Plaintiff’s response to Defendants’ Motion to Dismiss [ECF
42] is Monday November 27.
2. Last night everyone in Plaintiff’s counsel’s family (including Plaintiff’s counsel and her
5/6 y.o. kids) fell ill with food poisoning.
Case No. 1:23-cv-01339-RM-STV Document 47 filed 11/27/23 USDC Colorado pg 1 of 3
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3. Plaintiff’s counsel has been working on the response due today over the past week
since recovering from COVID herself just last weekend, and is still endeavoring today,
working from home, to get it finished in time. However today is also the deadline for
this Response to Defendants’ MTD in the 4 other related cases and with time getting
tight and everyone still quite sick at home it seems that extraordinary circumstances
may be conspiring to require another day (or two at the most) to get this task properly
completed across all 5 cases.
4. Counsel is requesting a 2-day extension to the existing deadline on Plaintiff’s
response to Defendants’ Motion to Dismiss, for a new filing deadline of Wednesday,
November 29, 2023.
5. Counsel has requested a previous extension due to her family first, and then a week
later, her, getting COVID. No party will be prejudiced by the relief sought herein and,
given the progress she’s already made drafting the response at issue since returning
to work last week, counsel is certain that no further extensions will be necessary.
WHEREFORE the Plaintiff respectfully requests a 2-day extension to the deadline for
filing Plaintiff’s Response to Defendants’ Motion to Dismiss (ECF 42), to November 29,
2023.
Respectfully submitted this 27th 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
Case No. 1:23-cv-01339-RM-STV Document 47 filed 11/27/23 USDC Colorado pg 2 of 3
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F: (970) 797-4008
E: sarah@lifeandlibertylaw.com
Counsel for Plaintiff
CERTIFICATE OF SERVICE
This is to certify that on November 27, 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
Case No. 1:23-cv-01339-RM-STV Document 47 filed 11/27/23 USDC Colorado pg 3 of 3