HomeMy WebLinkAbout2017CV884 - CHAYCE ANDERSON V. FCPS OFFICER JASON SHUTTERS - 109 - MOTION TO MODIFY SCHEDULING ORDERIN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 1:17-CV-00884-CMA-STV
CHAYCE AARON ANDERSON,
Plaintiff,
vs.
JASON SHUTTERS,
Defendant.
JOINT MOTION FOR LEAVE TO AMEND DEADLINES
IN THE SCHEDULING ORDER
The Parties respectfully request that this Court grant leave to amend the expert disclosure
and close of discovery deadlines in the Scheduling Order (ECF No. 103). In support of this
request, the undersigned represents that the Parties conferred on this matter and have no
objections pursuant to D.C.COLO.LCivR 7.1(a).
The Parties have been proceeding under the Scheduling Order. Due to unforeseen
scheduling conflicts and because the parties are continuing to work together to complete written
discovery, the Parties respectfully request additional time to meet the discovery and dispositive
motion deadlines. The Parties also respectfully request to reschedule the final pretrial conference
to accommodate the additional time sought to meet the discovery and dispositive motion
deadlines. This is the first motion for an extension of time in the present case by either Party.
Accordingly, the Parties respectfully request that the current deadlines be extended by forty-five
(45) days as follows:
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The Discovery Cut-off shall be April 4, 2019 (extended from February 18, 2019);
The Dispositive Motion Deadline shall be May 2, 2019 (extended from March 18, 2019);
Plaintiff shall designate all experts and provide opposing counsel with all information
specified in Fed. R. Civ. P. 26(a)(2) on or before February 1, 2019 (extended from
December 18, 2018);
Defendant shall designate all experts and provide opposing counsel with all information
specified in Fed. R. Civ. P. 26(a)(2) on or before March 4, 2019 (extended from January
18, 2019);
The Parties shall designate rebuttal experts on or before March 18, 2018 (extended from
February 1, 2019);
The Deadline for Interrogatories shall be March 4, 2019 (extended from January 18,
2019);
The Deadline for Requests for Production of Documents and/or Admissions shall be
March 4, 2019 (extended from January 18, 2019);
Defendant shall respond to Plaintiff’s First Set of Requests for Production no later than
January 27, 2019 (extended from December 13, 2019);
Plaintiff shall respond to Defendant’s First Set of Written Discovery no later than
January 28, 2019 (extended from December 14, 2018); and
The final pretrial conference shall be held in this case on a date at the Court’s
convenience (extended from May 13, 2019).
WHEREFORE, the parties respectfully request that this Court grant the Motion for Leave
to Amend Discovery Deadlines in the Scheduling Order.
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Dated this 12th day of December, 2018.
/s/ Christopher Casolaro_________________
Christopher Casolaro
Travis Jordan
Ll. Rhyddid Watkins
Heather Campbell Burgess
FAEGRE BAKER DANIELS LLP
1700 Lincoln Street, Suite 3200
Denver, Colorado 80203
Telephone: (303) 607-3500
Facsimile: (303) 607-3600
christopher.casolaro@faegrebd.com
travis.jordan@faegrebd.com
rhyddid.watkins@faegrebd.com
heather.burgess@faegrebd.com
Attorneys for Plaintiff
/s/ Mark Ratner
Mark S. Ratner, Esq.
HALL & EVANS, L.L.C.
1001 Seventeenth Street, Suite 300
Denver, Colorado 80202
ratnerm@hallevans.com
Attorney for Defendant
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CERTIFICATE OF SERVICE (CM/ECF)
I hereby certify that on this 12th day of December 2018, I filed the foregoing JOINT
MOTION FOR LEAVE TO AMEND DEADLINES IN THE SCHEDULING ORDER via
the Court’s electronic filing system, which shall serve notice to:
Mark S. Ratner, Esq.
HALL & EVANS, L.L.C.
1001 Seventeenth Street, Suite 300
Denver, Colorado 80202
Ratnerm@hallevans.com
s/ Carol Wildt
Legal Administrative Assistant
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