Loading...
HomeMy WebLinkAbout2016CV31096 - CITY OF FORT COLLINS, A COLORADO MUNICIPAL CORPORATION; AND POUDRE FIRE AUTHORITY, A COLORADO PUBLIC ENTITY V. KEITH GILMARTIN - 056 - MOTION FOR ENLARGEMENT OF TIME TO FILE TRIAL MANAGEMENT ORDER1 2655332.1 DISTRICT COURT, LARIMER COUNTY, COLORADO Larimer County Justice Center 201 La Porte Avenue Suite 100 Fort Collins, CO 80521 970-494-3500 ▲ COURT USE ONLY ▲ Plaintiffs: CITY OF FORT COLLINS, a Colorado municipal corporation; and POUDRE FIRE AUTHORITY, a Colorado public entity, v. Defendant: KEITH GILMARTIN, an individual. Kelley B. Duke, #35168 Benjamin J. Larson, #42540 IRELAND STAPLETON PRYOR & PASCOE, PC 717 17 th St. Suite 2800 Denver, Colorado 80202 Telephone: (303) 623-2700 Fax No.: (303) 623-2062 E-mail: kduke@irelandstapleton.com blarson@irelandstapleton.com SPECIAL COUNSEL FOR THE CITY OF FORT COLLINS; ATTORNEYS FOR POUDRE FIRE AUTHORITY Case No.: 2016CV31096 Div.: Ctrm: 3C PLAINTIFFS' UNOPPOSED MOTION FOR TWO-DAY ENLARGEMENT OF TIME TO FILE [PROPOSED] STIPULATED TRIAL MANAGEMENT ORDER Plaintiffs the City of Fort Collins, a Colorado municipal corporation (the "City"), and the Poudre Fire Authority, a Colorado public entity (the "Authority", collectively, "Plaintiffs") by and through their undersigned counsel, IRELAND STAPLETON PRYOR & PASCOE, PC, respectfully move for a two-day enlargement of time to file a proposed Trial Management Order and state as follows: DATE FILED: July 17, 2017 2:41 PM FILING ID: FBE753D3F578B CASE NUMBER: 2016CV31096 2 2655332.1 CERTIFICATE OF CONFERRAL Pursuant to C.R.C.P. 121 § 1-15(8), undersigned counsel certifies that he conferred with Mr. Gilmartin who indicated that he favors the relief requested. 1. This matter is set for a two-day trial commencing on August 14, 2017. Accordingly, the proposed Trial Management Order is due on or before July 17, 2017. Mr. Gilmartin has not provided Plaintiffs' counsel with his portion of the Trial Management Order, and he asked for additional time to file the Trial Management Order. 2. Pursuant to the Case Management Order, the parties are required to exchange witness and exhibit lists prior to the pretrial conference, scheduled for July 20, 2017 at 1:00 p.m. 3. The parties previously agreed to exchange witness and exhibit lists on July 19, 2017. 4. Plaintiffs request a brief extension of time, through and including July 19, 2017, in which to file the proposed Trial Management Order so that they can add Mr. Gilmartin's additions to the Trial Management Order. Further, the additional time will allow the parties to file their respective witness and exhibit lists with the proposed Trial Management Order in accordance with C.R.C.P. 16(f). 5. The requested enlargement is not requested for any improper purpose and will not prejudice the Defendant in this matter. WHEREFORE, Plaintiffs respectfully request an enlargement of time, through and including, Wednesday, July 19, 2017, to file a proposed Trial Management Order. A proposed order is filed herewith for the Court's convenience. Respectfully submitted this 17th day of July, 2017. 3 2655332.1 IRELAND STAPLETON PRYOR & PASCOE, PC Signed original on file at the office of Ireland Stapleton Pryor & Pascoe, PC /s/ Benjamin J. Larson Kelley B. Duke, #35168 Benjamin J. Larson, #42540 Special Counsel for the City of Fort Collins Attorneys for Poudre Fire Authority CERTIFICATE OF SERVICE I hereby certify that on this 17 th day of July, 2017, a true and correct copy of the foregoing PLAINTIFFS' UNOPPOSED MOTION FOR TWO-DAY ENLARGEMENT OF TIME TO FILE [PROPOSED] STIPULATED TRIAL MANAGEMENT ORDER was served via U.S. Postal Service, first class mail, postage prepaid and addressed as follows: Keith Gilmartin 3316 W. Vine Drive Fort Collins, CO 80521 And served via email to: keithgil2@gmail.com SIGNED ORIGINAL ON FILE AT THE OFFICE OF IRELAND STAPLETON PRYOR & PASCOE, PC /s/ Hannah Pick Hannah Pick