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HomeMy WebLinkAbout2018CV3112 - Sean Slatton V. Fort Collins Police Department, Todd Hopkins, Brandon Barnes And John Hutto - 101 - Unopposed Motion For Extension Of Time To File Plaintiff's Consolidated Response1 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. ______________________________________________________________________________ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE PLAINTIFF’S CONSOLIDATED RESPONSE TO DEFENDANTS’ MOTIONS TO DISMISS [Docs. 96 and 98] ______________________________________________________________________________ Plaintiff, by and through his attorneys, David A. Lane and Helen Oh, hereby submit the following UNOPPOSED Motion for Extension of Time to File Plaintiff’s Consolidated Response to Defendants’ Motions to Dismiss [Docs. 96 and 98] and states as follows: 1. Defendant Hopkins filed his Motion to Dismiss on January 13, 2020 [Doc. 96]. 2. Defendants Fort Collins, Colorado, Brandon Barnes, and John Hutto filed their Motion to Dismiss on January 16, 2020 [Doc. 98]. 3. Plaintiff’s counsel is diligently preparing their Consolidated Response to Defendants’ Motions to Dismiss but need additional time to finalize the consolidated response. 4. Counsel for Plaintiffs-Appellees, David A. Lane, in addition to the usual press of business, has spent a considerable amount of time working on a new sealed case he was recently appointed to in Western District of Texas; on January 20, he attended and prepared for oral arguments for Jones v. Manriquez, et al., Case No. 19-1144; Mr. Lane was out of town from Case 1:18-cv-03112-RBJ-STV Document 101 Filed 02/05/20 USDC Colorado Page 1 of 4 2 January 24-26 on a pre-planned trip for an unrelated matter, and on January 27, he testified in front of the Colorado State Senate regarding the death penalty repeal. 5. Counsel for Plaintiff, Helen Oh, will be primarily responsible for drafting the Consolidated Response to Defendants’ Motions to Dismiss. In addition to the usual press of business, she spent a considerable amount of time drafting a mediation statement and attended mediation for a pre-litigation case Patnode v. City of Fort Collins on February 3, 2020. She is also drafting discovery requests in Flores v. State of Colorado, et al., and a response to a Motion for Summary Judgment in another matter, Briones v. Adams County, et al. 6. No party will be prejudiced by the relief sought herein. CERTIFICATION PURSUANT TO D.C.COLO. LCivR. 7.1 7. Counsel for Plaintiff, Helen Oh, hereby certifies that she conferred with counsel for Defendants via email on February 4, 2020. Counsel for Defendants stated that Defendants do not oppose the relief requested herein. CERTIFICATION PURSUANT TO D.C.COLO. LCivR. 6.1(c) 8. Counsel for Plaintiff, Helen Oh, 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 UNOPPOSED Motion for Extension of Time to File Consolidated Response to Defendants’ Motions to Dismiss [Docs. 96 and 98], up to and including February 20, 2020, and for any other relief deemed just and proper. Respectfully submitted this 5th day of February 2020. KILLMER, LANE & NEWMAN, LLP s/ Helen Oh ________________________ Case 1:18-cv-03112-RBJ-STV Document 101 Filed 02/05/20 USDC Colorado Page 2 of 4 3 David A. Lane Helen Oh 1543 Champa Street, Suite 400 Denver, Colorado 80202 Phone: (303) 571-1000 dlane@kln-law.com hoh@kln-law.com Counsel for Plaintiffs Case 1:18-cv-03112-RBJ-STV Document 101 Filed 02/05/20 USDC Colorado Page 3 of 4 4 CERTIFICATE OF SERVICE I certify that on this 5th day of February, 2020 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 101 Filed 02/05/20 USDC Colorado Page 4 of 4