HomeMy WebLinkAbout2019CV30889 - ADAM WIEMOLD V. CITY OF FORT COLLINS - 020 - UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY BRIEF1
LARIMER COUNTY DISTRICT COURT
201 LAPORTE AVENUE, SUITE 100
FORT COLLINS, COLORADO 80521
COURT USE ONLY
Appeal from the Fort Collins Municipal Court
The Honorable Judge Kathleen M. Lane
Case No. 2018-0240752-MD
Defendant-Appellant:
ADAM WIEMOLD
v.
Plaintiff-Appellee:
PEOPLE OF THE STATE OF COLORADO
Adam Frank
FRANK AND SALAHUDDIN LLC
1741 High Street, Denver, CO 80218
adam@fas-law.com
Phone: 303-974-1084
Fax: 303-974-1085
Attorney Registration Number: 38979
In cooperation with the ACLU of Colorado
Case Number: 2019CV30889
UNOPPOSED MOTION FOR 21-DAY EXTENSION OF TIME TO FILE REPLY BRIEF
Mr. Wiemold, through counsel, requests that this Court grant him a 21-day extension of time
to file his reply brief. Mr. Wiemold has conferred with counsel for the City of Fort Collins
concerning this request, and the City does not object to the requested relief. As grounds, he states
the following:
1. This case is not the typical appeal of a municipal court conviction. As the Court has seen,
this appeal raises multiple complex constitutional issues of first impression in Colorado. As a
result, briefing in this case requires significantly more time and effort than the typical appeal
from municipal court.
2. Acknowledging this, the parties have cooperated with each other, not objecting to
extensions of time for filing briefs from the default deadlines contained in Crim. P 37.
Similarly, the City does not object to the relief requested herein.
3. While Mr. Wiemold’s Opening Brief was 22 pages, the City’s Answer Brief was 46 pages.
Responding to the arguments contained in this brief is a time-consuming task.
4. Because of the upheaval caused by the COVID-19 pandemic, counsel for Mr. Wiemold has
had to drastically change childcare arrangements, involving significantly increased amounts
DATE FILED: May 27, 2020 11:55 AM
FILING ID: 859A20F9A7332
CASE NUMBER: 2019CV30889
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of time where counsel’s children are home during the day. Given this, it is more difficult for
Mr. Wiemold’s counsel to dedicate the time required to address the issues in this appeal than
it would be under normal circumstances.
Wherefore, Mr. Wiemold asks that this Court grant him a 21-day extension to file the reply
brief in this case up to and including June 24, 2020.
Dated: May 27, 2020
Adam Frank, #38979
FRANK & SALAHUDDIN LLC
In Cooperation with the ACLU of Colorado
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Certificate of Service
I hereby certify that on May 27, 2020, I served a true and correct copy of the foregoing electronically
via the CCE e-filing system upon the trial court, as well as the following individuals, either directly
through CCE or via email:
Jill Heuser
jhueser@fcgov.com
Andrew Ringel
ringela@hallevans.com
______________________
Adam Frank
FRANK AND SALAHUDDIN LLC
Attorney for Defendant-Appellant