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HomeMy WebLinkAbout2018CV3112 - Sean Slatton V. Fort Collins Police Department, Todd Hopkins, Brandon Barnes And John Hutto - 066 - Motion For Extension Of Time To File Response To Defendants' Motions To Dismiss1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 1:18-cv-03112-RBJ-STV SEAN SLATTON, Plaintiff, v. TODD HOPKINS, BRANDON BARNES, JOHN HUTTO, and FORT COLLINS POLICE DEPARTMENT Defendants. ______________________________________________________________________________ MOTION FOR EXTENSION TO FILE PLAINTIFF’S RESPONSES TO DEFENDANTS’ MOTIONS TO DISMISS ______________________________________________________________________________ Plaintiffs, by and through their attorney, David A. Lane, hereby submits the following Motion for Extension of Time to File Plaintiff’s Responses to Defendants’ Motions to Dismiss and states as follows: 1. Undersigned counsel filed his Entry of Appearance in this case on August 26, 2019 [Doc. 65]. 2. Defendant Hopkins filed his Motion to Dismiss on June 14, 2019 [Doc. 28]. 3. Defendants Fort Collins, Colorado, Brandon Barnes, and John Hutto filed their Motion to Dismiss on June 17, 2019 [Doc. 39]. 4. Per the review of the filings in this case, Plaintiff’s responses to Defendants’ Motions to Dismiss are due on August 29, 2019 [Doc. 62]. 5. Plaintiff’s counsel is diligently reviewing the filings in this matter and preparing responses to Defendants’ Motions to Dismiss but needs additional thirty (30) days, up to and including September 30, 2019 to fully prepare the responses. Case 1:18-cv-03112-RBJ-STV Document 66 Filed 08/28/19 USDC Colorado Page 1 of 3 2 6. No party will be prejudiced by the relief sought herein. CERTIFICATION PURSUANT TO D.C.COLO. LCivR. 7.1 7. Staff for Plaintiff’s counsel, hereby certifies that he conferred with counsel for Defendants via email on August 27, 2019. Mark Ratner, counsel for Defendants Ft. Collins, Colorado, Barnes, and Hutto, does not oppose the relief sought herein. Marni Kloster, counsel for Defendant Hopkins, opposes the relief sought herein. CERTIFICATION PURSUANT TO D.C.COLO. LCivR. 6.1(c) 8. Counsel for Plaintiffs, David A. Lane, certifies that a copy of this Motion will be served contemporaneously on Plaintiffs upon the filing of this Motion. WHEREFORE, Plaintiffs respectfully request that the Court grant his Motion for Extension of Time to File Responses to Defendants’ Motions to Dismiss, up to and including September 30, 2019, and for any other relief deemed just and proper. Respectfully submitted this 28th day of August 2019. KILLMER, LANE & NEWMAN, LLP s/ David A. Lane ________________________ David A. Lane 1543 Champa Street, Suite 400 Denver, Colorado 80202 Phone: (303) 571-1000 dlane@kln-law.com Counsel for Plaintiffs Case 1:18-cv-03112-RBJ-STV Document 66 Filed 08/28/19 USDC Colorado Page 2 of 3 3 CERTIFICATE OF SERVICE I certify that on this 28th day of August, 2019 I filed a true and correct copy of the foregoing via CM/ECF which will generate e-mailed notice to the following: Marni Nathan Kloster Nicholas C. Poppe Nathan Dumm & Mayer, PC 7900 E. Union Ave., Ste 600 Denver, CO 80237-2776 303-691-3737 MKloster@ndm-law.com NPoppe@ndm-law.com Attorney for Defendant Todd Hopkins Mark Ratner Hall & Evans, LLC 1001 17th Street, Ste 300 Denver, CO 80202 303-628-3300 ratnerm@hallevans.com Counsel for Ft. Collins Defendants s/ Jamie Akard Paralegal Case 1:18-cv-03112-RBJ-STV Document 66 Filed 08/28/19 USDC Colorado Page 3 of 3