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HomeMy WebLinkAbout2018CV149 - SUTHERLAND V. CITY OF FORT COLLINS, STEVE MILLER & IRENE JOSEY - 026 - COUNTY DEFENDANTS MOTION FOR EXTENSIION OF TIME TO ANSWERLarimer County, Colorado, District Court Larimer County Justice Center 201 La Porte Avenue, Suite 100 Fort Collins, Colorado 80521-2761 (970) 494-3500 Court Use Only Plaintiff: ERIC SUTHERLAND, v. Defendant: THE CITY OF FORT COLLINS, a home rule municipality in the State of Colorado; STEVE MILLER, in his capacity as the Larimer County Assessor and all successors in this office; IRENE JOSEY, in her capacity as the Larimer County Treasurer and all successors to this office; and Indispensable Parties: THE TIMNATH DEVELOPMENT AUTHORITY, an Urban Renewal Authority; and COMPASS MORTGAGE CORPORATION, an Alabama company doing business in Colorado. Jeannine S. Haag, Reg. No. 11995 George H. Hass, Reg. No. 897 Larimer County Attorney’s Office 224 Canyon Ave., Suite 200 Post Office Box 1606 Fort Collins, Colorado 80522 Telephone (970) 498-7450 jeanninehaag@larimer.org wressue@larimer.org Case No. 18 CV 149 Courtroom 5B DEFENDANTS MILLER AND JOSEY’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT Defendants Miller and Josey (collectively, “County Defendants”) move this Court to extend the time to respond to Plaintiff’s Complaint to and including August 3, 2018 and in support states as follows: 1. County Defendants Answer is due July 18, 2018. DATE FILED: July 9, 2018 5:32 PM FILING ID: D759675D449A3 CASE NUMBER: 2018CV149 2. Counsel for County Defendants is out of town on a previously-scheduled vacation. 3. Additional time is needed to confer with clients and prepare a response to the Complaint. 4. No party will be prejudiced by the extension. 5. No previous extensions have been requested. 6. Plaintiff does not oppose the extension. WHEREFORE, County Defendants move this Court for an extension to and including August 3, 2018 in order to file their response to the Complaint. Dated: July 9, 2018 LARIMER COUNTY ATTORNEY’S OFFICE By: s/George H. Hass George H. Hass, Reg. No. 897 Attorney for Defendants Miller and Josey 224 Canyon Ave., Suite 200 Post Office Box 1606 Fort Collins, Colorado 80522 Telephone: (970) 498-7450 Facsimile: (970) 498-7430 ghass@larimer.org CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing DEFENDANTS MILLER AND JOSEY’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT was served on the following using the Colorado Courts E-Filing System and by placing in the U.S. Mail, postage prepaid, on the 9 th day of July , 2018: Eric Sutherland 3520 Golden Currant Boulevard Fort Collins, CO 80521 Eric R. Burris Brownstein Hyatt Farber Schreck, LLP 201 Third Street NW, Suite 1800 Albuquerque, NM 87102 eburris@bhfs.com Cole J. Woodward Brownstein Hyatt Farber Schreck, LLP 410 Seventeenth Street, Suite 2200 Denver, CO 80202-4432 cwoodward@bhfs.com John W. Mill Amanda Levin Milgrom Sherman & Howard L.L.C. 633 17th Street, Suite 3000 Denver, CO 80202 jmill@shermanhoward.com amilgrom@shermanhoward.com s/Jennifer D. Infeld