HomeMy WebLinkAbout2017CV493 - HOWARD V. CITY OF FORT COLLINS, ET AL - 021 - UNOPPOSED MOTION FOR A 14 DAY EXTENSION OF TIME TO FILE MOTION TO DISMISS CASEIN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 1:17-cv-00493-RPM
EUGENE HOWARD,
Plaintiff,
v.
CITY OF FORT COLLINS, and
KATHLEEN WALKER,
Defendants.
UNOPPOSED MOTION FOR A 14-DAY EXTENSION OF TIME TO
FILE MOTION TO DISMISS CASE
Plaintiff, Eugene Howard, by and through his attorney, MARK S. BOVE of the law firm
MARK S. BOVE, P.C. and Defendants, City of Fort Collins and Kathleen Walker, by and through
its and her attorneys, CATHY HAVENER GREER, and KATHERINE M.L. PRATT of
WELLS, ANDERSON & RACE, LLC, and JENNY LOPEZ FILKINS, SENIOR
ASSISTANT CITY ATTORNEY, CITY OF FORT COLLINS, and hereby submit this
Unopposed Motion for a 14-day Extension of Time to File Motion to Dismiss case, as follows:
1) Settlement negotiations were held between the parties and United States District
Court Magistrate Judge Michael Hegarty on October 19, 2017, and a settlement was reached.
2) The Court’s Minute Entry for Settlement (CM/ECF Docket #20) directed the parties
to file a motion to dismiss the case on or before November 15, 2017.
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3) The parties need an additional fourteen days within which to complete the
paperwork to dismiss Defendant Kathleen Walker and then to dismiss the remaining claims.
4) No previous extensions of time to file the dismissal paperwork has been requested.
5) The parties’ clients are being served copies of this Motion.
WHEREFORE, the parties respectfully request an extension of time to and including
November 29, 2017 for filing of the Motion to Dismiss this case, and for such other and further
relief as the Court deems proper.
Respectfully submitted this 13th day of November, 2017.
MARK S. BOVE, P.C.
S/ Mark S. Bove
Mark S. Bove
730 17th Street, Suite 365
Denver, CO 80202
T: 303-393-6666
Email: msbove@aol.com
ATTORNEY FOR PLAINTIFF
WELLS, ANDERSON & RACE, LLC
S/ Cathy Havener Greer
Cathy Havener Greer
Katherine M.L. Pratt
1700 Broadway, Suite 1020
Denver, CO 80290
T: 303-830-1212
Email: cgreer@warllc.com
Email: kpratt@warllc.com
S/ Jenny L. Lopez Filkins
Jenny L. Lopez Filkins
City Attorney's Office-Fort Collins
P.O. Box 580
Fort Collins, CO 80522
T: 970-416-2284
Email: jlopezfilkins@fcgov.com
ATTORNEYS DEFENDANTS
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on November 13, 2017, a true and correct copy of the above
and foregoing UNOPPOSED MOTION FOR A 14-DAY EXTENSION OF TIME TO FILE
MOTION TO DISMISS CASE was electronically filed with the Clerk of Court using the
CM/ECF system, which will send notification of such filing to the following email addresses:
Mark S. Bove, Esq.
Mark S. Bove, P.C.
730 17th Street, Suite 365
Denver, CO 80202
Email: msbove@aol.com
ATTORNEY FOR PLAINTIFF
and I hereby certify that I have mailed or served the document or paper to the following
non CM/ECF participants in the manner (mail, hand-delivery, etc.) indicated by the non-
participants name:
Via Electronic Mail
City of Fort Collins
Kathleen Walker
S/ Barbara McCall
Barbara McCall
Email: bmccall@warllc.com
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