HomeMy WebLinkAbout2016CV1308 - FTN - FORT COLLINS V. CITY OF FORT COLLINS - 012 - CITY'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO ANSWER OR OTHERWISE RESPONDIN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 16-cv-01308-RBJ-KLM
FREE THE NIPPLE – FORT COLLINS, an unincorporated association,
BRITTANY HOAGLAND, and
SAMANTHA SIX,
Plaintiffs,
v.
CITY OF FORT COLLINS, COLORADO,
Defendant.
______________________________________________________________________________
DEFENDANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO
ANSWER OR OTHERWISE RESPOND TO PLAINTIFFS’ COMPLAINT
AND PLAINTIFFS’ MOTION FOR A PRELIMINARY INJUNCTION
______________________________________________________________________________
Defendant City of Fort Collins, Colorado (“Fort Collins”), by its attorneys, Andrew D.
Ringel, Esq., Gillian Dale, Esq., and Christina S. Gunn, Esq., of Hall & Evans, LLC, hereby
submits this Unopposed Motion for Extension of Time to Answer or Otherwise Respond to the
Plaintiffs’ Complaint (“Complaint”) and Plaintiffs’ Motion for a Preliminary Injunction, as
follows:
1. Defendant City of Fort Collins, Colorado, was served with a summons and the
Plaintiffs’ Complaint on June 21, 2016. [ECF 11.] Accordingly, pursuant to the applicable Federal
Rules of Civil Procedure, Defendant’s response to the Plaintiffs’ Complaint is due on July 12,
2016. [See ECF 11.]
2. On the same date, Defendant City of Fort Collins, Colorado received notice
Plaintiffs filed a Motion for Preliminary Injunction on May 31, 2016. [ECF 2.]
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3. The undersigned counsel was recently retained to represent the Defendant and
needs additional time to investigate the Plaintiffs’ allegations, gather and evaluate existing
documentation, and consult with the Defendant to determine an appropriate strategy prior to
responding to the Plaintiffs’ Complaint and Plaintiffs’ Motion for Preliminary Injunction.
4. Accordingly, Defendant City of Fort Collins, Colorado requests an extension of 21
days until and including August 2, 2016, to answer or otherwise respond to the Plaintiffs’
Complaint and to respond to the Plaintiffs’ Motion for Preliminary Injunction. No party will be
prejudiced by this brief extension of time.
5. Pursuant to D.C.COLO.LCivR 7.1(A), prior to filing the instant Motion, the
undersigned counsel conferred with counsel for the Plaintiffs, David Lane, Esq. Mr. Lane
indicated the Plaintiffs do not object to this Motion.
6. Pursuant to D.C.Colo.LCivR 6.1(C) a copy of this motion has been served on the
undersigned’s client as indicated on the certificate of service.
WHEREFORE, Defendant City of Fort Collins, Colorado, respectfully requests this Court
extend the deadline for this Defendant to answer or otherwise respond to the Plaintiffs’ Complaint
and Jury Demand and to respond to the Plaintiffs’ Motion for Preliminary Injunction for 21 days
until and including August 2, 2016, and for all other and further relief as this Court deems just and
appropriate.
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Dated this 8th day of July, 2016.
Respectfully submitted,
s/ Andrew D. Ringel
Andrew D. Ringel, Esq.
Gillian Dale, Esq.
Christina S. Gunn, Esq.
HALL & EVANS, L.L.C.
1001 Seventeenth Street, Suite 300
Denver, Colorado 80202
Phone: (303) 628-3300
Fax: (303) 628-3368
ringela@hallevans.com
daleg@hallevans.com
gunnc@hallevans.com
ATTORNEYS FOR DEFENDANT
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CERTIFICATE OF SERVICE (CM/ECF)
I hereby certify that on this 8th
day of July, 2016, I electronically filed the foregoing with
the Clerk of Court using the CM/EFC system which will send notification of such filing to the
following e-mail addresses:
David A. Lane, Esq.
dlane@kln-law.com
Andy McNulty, Esq.
amcnulty@kln-law.com
Jessica K. Peck, Esq.
jessica@jpdenver.com
and I hereby certify that I have mailed or served the document or paper to the following non
CM/EFC participants in the manner indicated by the non-participant’s name:
Carrie Daggett, Esq. (via electronic mail)
City Attorney
City of Fort Collins
s/ Nicole Marion, Legal Assistant to
Andrew D. Ringel, Esq.
Gillian Dale, Esq.
Christina S. Gunn, Esq.
HALL & EVANS, L.L.C.
1001 Seventeenth Street, Suite 300
Denver, Colorado 80202
Phone: (303) 628-3300
Fax: (303) 628-3368
ringela@hallevans.com
daleg@hallevans.com
gunnc@hallevans.com
ATTORNEYS FOR DEFENDANT
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