HomeMy WebLinkAbout2018CV3204 - LORI FRANK V. CITY OF FORT COLLINS, TERENCE F. JONES AND JEROME SCHIAGER - 035 - PLAINTIFF'S PARTIAL UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO DISCOVERY REQUESTS1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 1:18-cv-03204-RBJ
LORI FRANK,
Plaintiff,
vs.
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.
PLAINTIFF’S PARTIAL UNOPPOSED MOTION FOR EXTENSION OF TIME TO
RESPOND TO DEFENDANT’S FIRST SET OF DISCOVERY REQUESTS
Plaintiff, Lori Frank, through her undersigned counsel, hereby requests an extension of
time until July 10, 2019 to submit her Response to Defendants’ First Set of Interrogatories and
Requests for Production of Documents. As grounds Plaintiff states as follows:
1. On May 24, 2019 Defendant’s submitted their first set of discovery requests to
Plaintiff’s and Plaintiff submitted her first set of discovery to Defendant, City of Fort Collins.
2. The Parties’ responses are due June 24, 2018.
3. On June 21, 2019 Defendant’s filed a Motion for a one-week extension to respond to
Plaintiff’s discovery.
4. Defendant’s stated in their Motion that “As a courtesy, the City would not oppose a
similar one-week extension on Plaintiff’s deadline to respond to Defendant’s discovery requests.".
5. Counsel for Plaintiff has conferred with Counsel for Defendants regarding an
extension of time until July 10, 2019 for Plaintiff to respond to Defendant’s discovery requests.
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6. Counsel for Defendant’s did not respond regarding the extension until July 10, 2019
for Plaintiff to respond to Defendants’ discovery requests.
7. Counsel for Plaintiff is currently out of the office and will not return until July 5,
2019 and will be unable to complete Plaintiff’s discovery responses until her return. Plaintiff
hereby requests an extension of time until July 10, 2019 in order to prepare Plaintiff’s responses to
Defendant’s discovery requests.
8. Plaintiff’s requests an extension of time will not cause undue delay and no party
will be prejudiced should the requested relief be granted.
WHEREFORE, Plaintiff respectfully requests that the Court grant her motion and extend
the deadline for her to respond to Defendants’ First Set of Interrogatories and Requests for
Production of Documents, up to and including July 10, 2019.
RESPECTFULLY SUMBITTED this 24th
day of June 2019.
ROBINSON & ASSOCIATES LAW OFFICE, LLC
s/Jennifer Robinson
Jennifer Robinson
Robinson & Associates Law Office, LLC 7900
E. Union Avenue, Suite 1100
Denver, CO 80237
(303) 872-3063
jrobinson@raemployment.com
ATTORNEY FOR PLAINTIFF
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CERTIFICATE OF SERVICE
I hereby certify that on June 24, 2019, a true and correct copy of the above and foregoing
PLAINTIFF’S PARTIAL UNOPPOSED MOTION FOR EXTENSION OF TIME TO
RESPOND TO DEFENDANT’S FIRST SET OF DISCOVERY REQUESTS was
electronically filed using the CM/ECF system, which will send notification of such filing to the
following email addresses:
Cathy Havener Greer
Kathryn a. Starnella
Wells, Anderson & Race, LLC
1700 Broadway, Suite 1020
Denver, CO 80290
Email: Cgreet@warllc.com
kstarnella@warllc.com
Attorneys for Defendant’s City of Fort
Collins and Terence F. Jones
Jenny Lopez Filkins
Senior Assistant City Attorney
City of Fort Collins
300 LaPorte Avenue
Fort Collins, CO 80521
Attorney for Defendant City of Fort Collins
s/ Jennifer Robinson
Jennifer Robinson
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