HomeMy WebLinkAbout2018CV01 - SUTHERLAND V. CITY OF FORT COLLINS, ET AL - 032 - NEXT CHAPTER RESPONSE TO MOTION FOR CLARIFICATIONFort Collins Municipal Court
215 N. Mason
Fort Collins, CO 80521
(970) 221-6800
Plaintiffs: Erik Sutherland and Brian Dwyer
V.
COURT USE ONLY
Defendants: THE CITY COUNCIL OF THE CITY OF
FORT COLLINS, the governing body of a Colorado
Municipal corporation; and THE ADMINISTRATION
BRANCH OF THE CITY OF FORT COLLINS, by and
through its City Manager, Darin Atteberry
Intervenor: Next Chapter Properties, LLC, an Illinois
limited liability company.
Jeffrey B. Cullers, No. 41969
Herms & Herrera, LLC
Case Number: 2018civi101
Attorneys for Next Chapter Properties, LLC
3600 S. College Ave., Suite 204
Fort Collins, CO 80525
Phone Number: 970-498-9999
Fax Number: 970-472-5365
E-Mail: jeff@hhlawoffice.com
NEXT CHAPTER PROPERTIES, LLC's
RESPONSE TO THE MOTION FOR CLARIFICATION
Comes now Next Chapter Properties, LLC, ("Next Chapter"), by and through its attorney
Jeffrey Cullers of the law firm Herms & Herrera, LLC, and submits this Response to the Motion
for Clarification filed by Plaintiff Eric Sutherland on November 21, 2018, as follows:
Next Chapter joins in the City's Response to the Motion for Clarification. Next Chapter
notes that Mr. Sutherland filed the motion the afternoon of the day before Thanksgiving, less
than two hours after sending an email conferring regarding the same. Accordingly, since there
was no meaningful conferral, the Court should strike the Motion on this basis. Next Chapter
agrees with the City that the Motion is frivolous and unnecessary. Accordingly, it would be
proper for the Court to strike the Motion on that basis, as well.
Respectfully submitted this 26th day of November, 2018
HE HE RA,LLC
e ullers, #41969
ttorney for Intervenors
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on the 26th day of November, 2018 a true and
correct copy of the above and foregoing was filed via email and served on all parties via email
as follows:
Eric Sutherland
3520 Golden Currant
Fort Collins, CO 80521
sutherix(j )yahoo.com
Brian Dwyer
2001 S. College Ave.
Fort Collins, CO 80525
bdwyerl199t ginail.com
Kimberly Schutt
Wick & Trautwein
323 South College Avenue #3
Fort Collins, CO 8052�'
kschuttg,wickla«-. cam
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