HomeMy WebLinkAbout2018CV3204 - LORI FRANK V. CITY OF FORT COLLINS, TERENCE F. JONES AND JEROME SCHIAGER - 061 - UNOPPOSED MOTION FOR EXTENSION OF TIME FOR REVIEW AND SIGNING OF DEPOSITION TRANSCRIPT1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 1:18-cv-03204-RBJ-NRN
LORI FRANK,
Plaintiff,
vs.
CITY OF FORT COLLINS, a municipality; and
JEROME SCHIAGER, former Deputy Chief of Police, in his individual capacity,
Defendants.
UNOPPOSED MOTION FOR EXTENSION OF TIME UNDER FED. R. CIV. P. 30(e)
FOR REVIEW AND SIGNING OF DEPOSITION TRANSCRIPT
Defendant City of Fort Collins, by its counsel, requests an extension of the deadline for
review and signing of the deposition transcript of Teresa Roche from December 16, 2019 to
January 16, 2020, and as grounds for this request states:
1. The deposition of Ms. Roche was taken November 7, 2019.
2. The court reporter sent the transcript of the Roche deposition and related exhibits
to the Fort Collins City Attorney on November 15, 2019.
3. Ms. Roche underwent surgery on November 20, 2019 and will be on medical leave
through late January 2020.
4. Ms. Roche requires additional time beyond the normal 30 days permitted in Fed.
R. Civ. P 30(e) to review her deposition, but intends to complete the review while she is on medical
leave.
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5. No party will be prejudiced by this extension of time. The City has not requested
a similar extension of time for any other deponent to review her deposition transcript.
6. Plaintiff’s counsel does not oppose this request.
WHEREFORE, Defendant City of Fort Collins respectfully requests an extension of time
to and including January 16, 2020 for Teresa Roche to review and sign the transcript to her
deposition, and for such other relief as this Court deems proper.
Dated this 21st day of November, 2019.
Respectfully submitted,
S/Cathy Havener Greer
Cathy Havener Greer
Kathryn A. Starnella
Wells, Anderson & Race, LLC
1700 Broadway, Suite 1020
Denver, CO 80290
Telephone: (303) 830-1212
Email: cgreer@warllc.com; kstarnella@warllc.com
S/Jenny Lopez Filkins
Jenny Lopez Filkins
Senior Assistant City Attorney
City of Fort Collins
300 LaPorte Avenue
Fort Collins, CO 80521
Telephone: (970) 221-6520
Email: jlopezfilkins@fcgov.com
Attorneys for Defendant City of Fort Collins
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on November 21, 2019, a true and correct copy of the above
and foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME UNDER FED. R. CIV.
P. 30(e) FOR REVIEW AND SIGNING OF DEPOSITION TRANSCRIPT was electronically
filed with the Clerk of the Court using the CM/ECF system, which will send notification of such
filing to the following email addresses
Jennifer Robinson, Esq.
Robinson & Associates Law Offices, LLC
7900 E. Union Avenue, Suite 1100
Denver, CO 80237
Email: jrobinson@raemployment.com
Robert M. Liechty, Esq.
Robert M. Liechty PC
1800 Gaylord St
Denver, CO 80206
Email: rliechty@crossliechty.com
Attorneys for Plaintiff
David R. DeMuro, Esq.
Vaughan & DeMuro
720 South Colorado Boulevard
Penthouse, North Tower
Denver, CO 80246
Email: ddemuro@vaughandemuro.com
Sara L. Cook, Esq.
Vaughan & DeMuro
111 South Tejon, Suite 545
Colorado Springs, CO 80903
Email: scook@vaughandemuro.com
Attorneys for Defendant Schiager
S/Barbara McCall
Barbara McCall
bmccall@warllc.com
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