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
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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