HomeMy WebLinkAbout2018CV3204 - LORI FRANK V. CITY OF FORT COLLINS, TERENCE F. JONES AND JEROME SCHIAGER - 011 - DEFENDANT SCHIAGER'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO COMPLAINTIN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 18-cv-03204-NRN
LORI FRANK,
Plaintiff,
v.
CITY OF FORT COLLINS, a municipality;
TERENCE F. JONES, former Interim Chief of Police, in his individual capacity; and
JEROME SCHIAGER, former Deputy Chief of Police, in his individual capacity,
Defendants.
_________________________________________________ _____________________
DEFENDANT SCHIAGER’S UNOPPOSED MOTION FOR
EXTENSION OF TIME TO FILE RESPONSE TO COMPLAINT
_______________________________________________________________________
Defendant JEROME SCHIAGER, former Deputy Chief of Police, hereby moves this
Court for an order extending the time through and including January 31, 2019, to file an
answer, motion, or other responsive pleading and, as grounds therefor, states the
following:
CERTIFICATION
Pursuant to D.C.COLO.LCivR 7.1(a), Defendant Schiager’s counsel has conferred
with Plaintiff’s counsel. Defendant Schiager’s counsel certifies that Plaintiff has no
objection to this motion.
Pursuant to D.C.COLO.LCivR 6.1(c), Defendant Schiager’s counsel is providing a
copy of this motion to his client, as set forth in the certificate of service below.
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MOTION
1. Defendant Schiager’s answer or other response is purportedly due on
January 4, 2019.
2. Undersigned counsel confirmed on January 3, 2019, that he has been
retained to defend Mr. Schiager. He was able to speak with Mr. Schiager for the first time
on January 3.
3. Undersigned counsel needs to meet in person with Mr. Schiager and obtain
materials relating to this matter to prepare an appropriate defense.
4. Defendant Schiager requests an extension of time through and including
January 31, 2019, in which to file an answer, motion, or other responsive pleading.
WHEREFORE, Defendant Schiager requests that the Court issue an order granting
him an extension of time through and including January 31, 2019, in which to file an
answer, motion, or other responsive pleading in this action.
Respectfully submitted,
Date: 01/03/19 s/ David R. DeMuro
David R. DeMuro
VAUGHAN & DeMURO
720 South Colorado Boulevard
Penthouse, North Tower
Denver, CO 80246
303-837-9200 (phone)
ddemuro@vaughandemuro.com (e-mail)
ATTORNEY FOR DEFENDANT SCHIAGER
2
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CERTIFICATE OF SERVICE
I hereby certify that on this 3rd day of January, 2019, I electronically filed the
foregoing with the Clerk of Court using the CM/ECF system which will send notification of
such filing to the following e-mail addresses:
Jennifer Robinson
jrobinson@raemployment.com
Cathy Havener Greer
cgreer@warllc.com; bmccall@warllc.com; pcallies@warllc.com
and I hereby certify that the foregoing is being served via private email address on the
following:
Jerome Schiager
[by email]
s/ David R. DeMuro
David R. DeMuro
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