HomeMy WebLinkAbout2016CV1308 - FTN - FORT COLLINS V. CITY OF FORT COLLINS - 025 - UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY TO MOTION FOR PRELIMINARY INJUNCTION AND MOTION TO DISMISS1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 16-cv-1308-RBJ-KLM
FREE THE NIPPLE – FORT COLLINS, an unincorporated association,
BRITTIANY HOAGLAND, and
SAMANTHA SIX,
Plaintiffs,
v.
CITY OF FORT COLLINS, COLORADO,
Defendant.
______________________________________________________________________________
UNOPPOSED MOTION FOR EXTENSION TO FILE PLAINTIFFS’ REPLY TO
DEFENDANT’S RESPONSE TO PLAINTIFFS’ MOTION FOR PRELIMINARY
INJUNCTION AND RESPONSE TO DEFENDANTS’ MOTION TO DISMISS
______________________________________________________________________________
Plaintiffs, by and through their attorneys, David A. Lane and Andy McNulty, of
KILLMER, LANE & NEWMAN, LLP, hereby submit the following Unopposed Motion for
Extension of Time to File Plaintiffs’ Reply to Defendant’s Response to Plaintiffs’ Motion for
Preliminary Injunction and Response to Defendants’ Motion to Dismiss, and state as follows:
1. Plaintiffs’ Reply to Defendant’s Response to Plaintiffs’ Motion for Preliminary
Injunction is currently due on or before August 19, 2016, inclusive of three days for service.
2. Plaintiffs’ Response to Defendants’ Motion to Dismiss is currently due on or
before August 26, 2016, inclusive of three days for service.
3. Counsel for Plaintiffs have been diligently working on both motions, but require
additional time, up to and including September 2, 2016.
Case 1:16-cv-01308-RBJ Document 25 Filed 08/17/16 USDC Colorado Page 1 of 2
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4. The length of Defendant’s Response to Plaintiffs’ Motion for Preliminary
Injunction and Motion to Dismiss necessitates that Plaintiffs’ counsel spend additional time
replying and responding.
5. No party will be prejudiced by the relief sought herein.
CERTIFICATION PURSUANT TO D.C.COLO. LCivR. 7.1
6. Counsel for Plaintiffs, Andy McNulty, hereby certifies that she conferred with
counsel for Defendant, Gillian Dale, via email on August 17, 2016. Defendant does not oppose
the relief sought herein.
CERTIFICATION PURSUANT TO D.C.COLO. LCivR. 6.1(c)
9. Counsel for Plaintiffs, Andy McNulty, certifies that a copy of this Motion will be
served contemporaneously on Plaintiffs upon the filing of this Motion.
WHEREFORE, Plaintiffs respectfully request that the Court grant their Motion for
Extension of Time to File Plaintiffs’ Reply to Defendant’s Response to Plaintiffs’ Motion for
Preliminary Injunction and Response to Defendants’ Motion to Dismiss, up to and including
September 2, 2016, and for any other relief deemed just and proper.
Respectfully submitted this 17th day of August 2016.
KILLMER, LANE & NEWMAN, LLP
s/ Andy McNulty
________________________
David A. Lane
Andrew McNulty
1543 Champa Street, Suite 400
Denver, Colorado 80202
Phone: (303) 571-1000
dlane@kln-law.com
amcnulty@kln-law.com
Counsel for Plaintiffs
Case 1:16-cv-01308-RBJ Document 25 Filed 08/17/16 USDC Colorado Page 2 of 2