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HomeMy WebLinkAbout2017CV884 - CHAYCE ANDERSON V. FCPS OFFICER JASON SHUTTERS - 125 - PLAINTIFF'S UNOPPOSED MOTION FOR EXTENSION OF PRE-TRIAL ORDER DEADLINE AND PRE-TRIAL CONFERENCEIN 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. PLAINTIFF’S UNOPPOSED MOTION FOR EXTENSION OF PRE-TRIAL ORDER DEADLINE AND PRE-TRIAL CONFERENCE Plaintiff respectfully requests that the Court grant this motion to extend the pre-trial order deadline and the pre-trial conference, which were previously set by order on February 27, 2019 (ECF No. 117). In support of this request, the undersigned represents that the Parties conferred on this matter pursuant to D.C.COLO.LCivR 7.1(a) and have no objections. This is Plaintiff’s first motion for an extension of time since counsel was appointed for Plaintiff, notwithstanding one joint motion for extension of time in December 2018 (ECF No. 109). Defendant has filed two unopposed motions for extensions of time, both of which were granted, including most recently on May 15, 2019 (ECF Nos. 115, 119, 121). In the Court’s May 15 Order, the dispositive motion deadline was extended to July 5, 2019 (ECF No. 121). Counsel for Defendant recently represented that he intends to file a motion for summary judgment. Thus, Defendant’s anticipated motion for summary judgment will not be fully briefed until approximately August 9, 2019. Accordingly, Plaintiff respectfully requests Case 1:17-cv-00884-CMA-STV Document 125 Filed 07/03/19 USDC Colorado Page 1 of 3 2 US.123779459.01 that the current deadline to file the pre-trial order (set for July 15, 2019) and the pre-trial conference (set for July 22, 2019) be extended until after briefing of the anticipated summary judgment motion is completed, on dates at the Court’s convenience, on or after September 9, 2019. WHEREFORE, Plaintiff respectfully requests that this Court grant his Unopposed Motion for Extension of Pre-Trial Order Deadline and Pre-Trial Conference. Dated this 3rd day of July, 2019. s/Christopher J. Casolaro_____________ Christopher J. Casolaro Travis Jordan Heather Campbell Burgess Alexandra Lakshmanan FAEGRE BAKER DANIELS LLP 1144 Fifteenth Street, Suite 3400 Denver, CO 80202 Telephone: (303) 607-3500 Facsimile: (303) 607-3600 christopher.casolaro@faegrebd.com travis.jordan@faegrebd.com heather.burgess@faegrebd.com allie.lakshmanan@faegrebd.com Attorneys for Plaintiff Case 1:17-cv-00884-CMA-STV Document 125 Filed 07/03/19 USDC Colorado Page 2 of 3 3 US.123779459.01 CERTIFICATE OF SERVICE The undersigned certifies that on July 3, 2019, a true and correct copy of the foregoing PLAINTIFF’S UNOPPOSED MOTION FOR EXTENSION OF PRE-TRIAL ORDER DEADLINE AND PRE-TRIAL CONFERENCE was served on the following counsel of record via the Court’s CM/ECF e-file system: Mark S. Ratner, Esq. HALL & EVANS, L.L.C. 1001 Seventeenth Street, Suite 300 Denver, Colorado 80202 Ratnerm@hallevans.com s/Vanessa Sanchez________________ Paralegal Case 1:17-cv-00884-CMA-STV Document 125 Filed 07/03/19 USDC Colorado Page 3 of 3