HomeMy WebLinkAbout2023-cv-1343 - Elias V. V. City Of Fort Collins, Et Al. - 069 - Pl's Unopposed Motion To Amend Scheduling Order To Extend Discovery Deadlines 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 23-CV-1343-GPG-KAS
HARRIS ELIAS,
Plaintiff,
v.
CITY OF FORT COLLINS,
JASON HAFERMAN, and
SERGEANT ALLEN HEATON
Defendants.
PLAINTIFF’S UNOPPOSED MOTION TO AMEND SCHEDULING ORDER TO
EXTEND DISCOVERY DEADLINES
Plaintiff Harris Elias, by and through his attorney, respectfully submits this
Unopposed Motion to Amend Scheduling Order to Extend Discovery Deadlines, and in
support of the same, states as follows:
1. The current expert disclosure deadlines are:
a. February 12, 2024 for Plaintiff’s Affirmative Expert Disclosure
b. March 12, 2024 for Defendants’ Affirmative and Rebuttal Disclosures
c. April 12, 2024 for Plaintiff’s Rebuttal Disclosures
d. May 11, 2024 Discovery Cut-off and 702 and 704 Motions
e. June 25, 2024 Dispositive Motion Deadline
2. In addition to this matter, there are four other lawsuits against the Defendants also
pending (Notice of Related Cases, ECF 2).
Case No. 1:23-cv-01343-GPG-KAS Document 69 filed 02/08/24 USDC Colorado pg 1 of 3
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3. The parties have discussed their intent to try and keep the discovery deadlines of the
four cases aligned so long as it continues to make sense to do so.
4. The current expert deadlines in the other lawsuits are:
a. April 5, 2024 for Plaintiff’s Affirmative Expert Disclosure
b. May 7, 2024 for Defendants’ Affirmative and Rebuttal Disclosures
c. June 4, 2024 for Plaintiff’s Rebuttal Disclosures
d. July 1, 2024 for Discovery Cut-Off
e. August 9, 2024 Dispositive Motion Deadline
5. Plaintiff respectfully requests that the same extensions/amendments listed above from
the related cases be adopted in the Scheduling Order for the instant matter (ECF 35).
6. Plaintiff also requests that 702 and 704 Motions follow the same extension while also
complying with the Practice Standards which would make the deadline July 4, 2024,
which is 30 days after Rebuttal Expert Witness Disclosures.
7. Conferral: Counsel has conferred with counsel for Defendants and is authorized to
state that they do not oppose the relief requested herein.
8. The extension will not unduly delay these proceedings or otherwise interfere with the
administration of justice.
9. No party will be prejudiced by the relief sought herein.
WHEREFORE Plaintiff Harris Elias, respectfully requests an extension to the
discovery deadlines.
Respectfully submitted this 8th day of February, 2024.
/s/ Sarah Schielke
Sarah Schielke
The Life & Liberty Law Office LLC
Case No. 1:23-cv-01343-GPG-KAS Document 69 filed 02/08/24 USDC Colorado pg 2 of 3
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1055 Cleveland Avenue
Loveland, CO 80537
Telephone: (970) 493-1980
FAX: (970) 797-4008
Email: sarah@lifeandlibertylaw.com
Attorney for Plaintiff Harris Elias
CERTIFICATE OF SERVICE
This is to certify that on February 8, 2024, 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
and Sergeant Allen Heaton
Yulia Nikolaevskya
Jonathan Abramson
SGR, LLC
Attorneys for Jason Haferman
Harris Elias
Plaintiff
/s/ Madie Baskin
Madie Baskin,
Paralegal for Sarah Schielke
Case No. 1:23-cv-01343-GPG-KAS Document 69 filed 02/08/24 USDC Colorado pg 3 of 3