Loading...
HomeMy WebLinkAbout2017CV884 - CHAYCE ANDERSON V. FCPS OFFICER JASON SHUTTERS - 112 - UNOPPOSED MOTION TO CONDUCT DEPOSITON OF INCARCERATED PERSON3439103.1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 17-cv-00884-CMA-STV CHAYCE AARON ANDERSON, Plaintiff, v. JASON SHUTTERS, Defendant. _____________________________________________________________________ DEFENDANT JASON SUTTHER’S UNOPPOSED MOTION TO CONDUCT A DEPOSITION OF AN INCARCERATED INMATE PLAINTIFF PURSUANT TO FED. R. CIV. P. 30(a)(2)(B) ______________________________________________________________________ Defendant Jason Shutters, by and through his attorney, Hall & Evans, L.L.C., submits the following as his Motion to Conduct A Deposition of an Incarcerated Inmate Plaintiff, and as grounds therefor state as follows: Certificate of Compliance with D.C.COLO.LCivR 7.1(A) Pursuant to D.C.COLO.LCivR 7.1(A), the undersigned counsel conferred with counsel for the Plaintiff. Plaintiff does not oppose the requested relief. 1. Pursuant to Fed. R. Civ. P. 30(a)(2)(B), an order from this Court is required for Defendant to conduct the deposition of the Plaintiff, who is incarcerated by the Colorado Department of Corrections. Plaintiff is currently located at the Arkansas Valley Correctional Facility, 12750 CO-96, Ordway, CO 81034. Case 1:17-cv-00884-CMA-STV Document 112 Filed 12/21/18 USDC Colorado Page 1 of 3 2 3439103.1 2. Defendant respectfully requests this Court issue an order allowing Defendant to depose Plaintiff at his current correctional facility or any subsequent correctional facility where he may be moved after the entry of an appropriate order. WHEREFORE, Defendant respectfully requests this Court issue an order allowing the deposition of Plaintiff pursuant to F.R.C.P. 30(a)(2)(B), and for all other and further relief as this Court deems necessary. Dated: December 21, 2018. Respectfully Submitted Duly Signed original in the file located at Hall & Evans, LLC /s/ Mark S. Ratner Mark S. Ratner, #38517 Hall & Evans, LLC 1001 Seventeenth Street, Suite 300 Denver, Colorado 80202 Attorneys for Defendant Jason Shutters Case 1:17-cv-00884-CMA-STV Document 112 Filed 12/21/18 USDC Colorado Page 2 of 3 3 3439103.1 CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on this 21st of December, 2018, I served via email the foregoing DEFENDANT JASON SUTTHER’S UNOPPOSED MOTION TO CONDUCT A DEPOSITION OF AN INCARCERATED INMATE PLAINTIFF PURSUANT TO FED. R. CIV. P. 30(a)(2)(B) to the following: Ll. Rhyddid Watkins, Esq. Christopher J. Casolaro, Esq. Travis S. Jordan, Esq. FAEGRE BAKER DANIELS LLP 1700 Lincoln Street, Suite 3200 Denver, CO 80203 Heather Campbell Burgess, Esq. FAEGRE BAKER DANIELS LLP 311 South Wacker Drive Suite 4400 Chicago, IL. 60606-6622 s/ Rochelle Gurule Legal Assistant to Mark S. Ratner, Esq. Of Hall & Evans, LLC Case 1:17-cv-00884-CMA-STV Document 112 Filed 12/21/18 USDC Colorado Page 3 of 3