HomeMy WebLinkAbout2019-cv-901 - Surat v. City of Fort Collins, et al. - 090 - DEFENDANT'S UNOPPOSED MOTION FOR EXTENSION OF TIMEIN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 19-cv-00901-WJM-NRN
MICHAELLA LYNN SURAT,
Plaintiff,
v.
RANDALL KLAMSER, in his individual capacity
Defendant.
_____________________________________________________________________
DEFENDANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME
______________________________________________________________________
Defendant RANDALL KLAMSER, in his individual capacity, by and through his
counsel, Mark S. Ratner, Esq., Gillian Dale, Esq., and Brenden Desmond, Esq., of Hall &
Evans, L.L.C., hereby submits the following Unopposed Motion for Extension of Time 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 Plaintiff. Counsel for Plaintiff does not oppose the relief sought in this Motion.
1. The scheduling order in this matter provides for a March 6, 2020 deadline
for Defendant’s expert disclosures. (ECF No. 61).
2. Due to the voluminous nature of the information in this matter, the Defendant
requires an additional 7 days for disclosure of his experts.
3. The parties are continuing to engage in discovery, including depositions and
document production. A 7-day extension of time will not interfere with the on-going discovery of
this matter.
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4. Pursuant to D.C.Colo.LCiv.R. 6.1(c), the undersigned counsel has served their
client’s representative with a copy of this Motion as reflected on the accompanying certificate of
service.
5. WHEREFORE, for all the foregoing reasons, Defendant respectfully requests an
extension of time until March 13, 2020, to complete his expert disclosures, and for entry of all
other relief as this Court deems just and appropriate.
Dated this 6th day of March, 2020.
Respectfully submitted,
s/ Mark Ratner
Mark S. Ratner, Esq.
Gillian Dale, Esq.
Brenden Desmond, Esq.
Hall & Evans, L.L.C.
1001 17th
Street, Suite 300
Denver, CO 80202
303-628-3300
Fax: 303-628-3368
ratnerm@hallevans.com
daleg@hallevans.com
desmondb@hallevans.com
ATTORNEYS FOR DEFENDANTS
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CERTIFICATE OF SERVICE (CM/ECF)
I HEREBY CERTIFY that on the 6th day of March, 2020, 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:
David Lane
Andrew McNulty
Helen S Oh
Killmer, Lane & Newman, LLP
1543 Champa St, Suite 400
Denver, CO 80202
303-571-1000 Phone
303-571-1001 Fax
dlane@kln-law.com
amcnulty@kln-law.com
hoh@kln-law.com
Attorneys for Plaintiff
Randall Klamser, Defendant
via Email
s/ Cindy Blanton, Legal Assistant of
Hall & Evans, L.L.C.
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