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
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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.
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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