HomeMy WebLinkAbout2016CV1308 - FTN - FORT COLLINS V. CITY OF FORT COLLINS - 028 - PLAINTIFFS' MOTION FOR LEAVE TO EXCEED PAGE LIMITATION FOR REPLIES1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 16-cv-1308
FREE THE NIPPLE – FORT COLLINS, an unincorporated association,
BRITTIANY HOAGLAND, and
SAMANTHA SIX,
Plaintiffs,
v.
CITY OF FORT COLLINS, COLORADO,
Defendant.
UNOPPOSED MOTION FOR LEAVE TO EXCEED PAGE LIMITATION REGARDING
PLAINTIFFS’ REPLY TO DEFENDANT’S RESPONSE TO
PLAINTIFFS’ MOTION FOR PRELIMINARY INJUNCTION
Plaintiffs, by and through their counsel David A. Lane, Andy McNulty, and Jessica Peck,
hereby submit the following Unopposed Motion for Leave to Exceed Page Limitation Regarding
Plaintiffs’ Reply to Defendant’s Response to Plaintiffs’ Motion for Preliminary Injunction and
state in support:
1. Plaintiffs filed a Motion for Preliminary Injunction on May 31, 2016. See [Doc. 2].
Defendant responded on August 2, 2016. See [Doc. 19]. Plaintiffs’ reply is due to this Court on
August 2, 2016.
2. Defendant’s Response to Plaintiffs’ Motion for Preliminary Injunction was thirty-two
pages in total. See [Doc. 19].
3. Counsel for Plaintiffs have been diligently working to consolidate Plaintiffs’ reply to
Defendant’s Response to Plaintiffs’ Motion for Preliminary Injunction, but request leave to
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exceed the page limit in Judge R. Brooke Jackson’s Civil Practice Standards so Defendant’s
Response is properly replied to.
4. Specifically, Counsel for Plaintiff request leave to exceed the page limitations by three
pages, so that they may file a Reply that is eight pages in length.
5. No party will be prejudiced by the granting of this Motion.
CERTIFICATION PURSUANT TO D.C. COLO. LCivR.7.1
Counsel for Plaintiff, Andy McNulty, certifies that he conferred with Andre D. Ringel, counsel
for Defendant, via email on August 26, 2016. Defendant does not oppose the relief sought
herein.
WHEREFORE, Plaintiff respectfully requests that this Court grant their Unopposed
Motion for Leave to Exceed Page Limitation Regarding Plaintiffs’ Reply to Defendant’s
Response to Plaintiffs’ Motion for Preliminary Injunction, and for any other relief deemed just
and proper.
DATED this 29th day of August, 2016.
Respectfully submitted,
KILLMER, LANE & NEWMAN, LLP
s/ Andy McNulty
___________________________
David A. Lane
Andy McNulty
1543 Champa Street, Suite 400
Denver, CO 80202
(303) 571-1000
dlane@kln-law.com
amcnulty@kln-law.com
Jessica K. Peck, Esq.
JESSICA K. PECK, ATTORNEY AT LAW, LLC
Office: 303-331-3413
3773 Cherry Creek North Drive, Suite 575
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Denver, CO 80209
jessica@jpdenver.com
Attorneys for Plaintiffs
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