HomeMy WebLinkAbout2020CV115 - STACY LYNNE V. NOAH BEALS AND THE CITY OF FORT COLLINS - 011 - SECOND MOTION FOR ENLARGEMENT OF TIME TO RESPONDDISTRICT COURT, LARIMER COUNTY, COLORADO
Larimer County Justice Center
201 Laporte Avenue, Suite 100
Fort Collins, CO 80521-2761
(970) 498-6100
Plaintiff: STACY LYNNE
v.
Defendants:
NOAH BEALS, CITY OF FORT COLLINS
COURT USE ONLY
Andrew W. Callahan, #52421
WICK & TRAUTWEIN, LLC
P.O. Box 2166
Fort Collins, CO 80522
Phone: (970) 482-4011
Email: acallahan@wicklaw.com
Case Number: 2020 CV 115
Courtroom: 3B
DEFENDANTS’ SECOND UNOPPOSED MOTION FOR ENLARGEMENT
OF TIME TO FILE RESPONSIVE PLEADING
COMES NOW, the Defendants, Noah Beals and the City of Fort Collins, by and through
counsel, Wick & Trautwein, LLC, and respectfully submits the following unopposed motion for
enlargement of time for the defendants to file their responsive pleadings to the Plaintiff’s
Amended Complaint. In support hereof, Defendants state as follows:
1. RULE 121 CERTIFICATION: Undersigned counsel for the Defendants hereby
advises the Court that he has conferred with Plaintiff about the enlargement of time requested in
this motion. Undersigned counsel is authorized to state that Plaintiff has consented to the relief
requested herein.
2. Plaintiff has filed an Amended Complaint in this matter. Defendants’ response to the
Amended Complaint is due on or about March 31, 2020. Defendants request an enlargement of
time to April 7, 2020 for all defendants to file a responsive pleading in this case.
3. This motion is made in good faith and in cooperation with other parties in this case. No
prejudice should be incurred to any party, as reflected by the consent and agreements described
above.
Respectfully submitted this 23
rd
day of March, 2020.
DATE FILED: March 23, 2020 3:55 PM
FILING ID: D50E0653C7BB6
CASE NUMBER: 2020CV115
2
WICK & TRAUTWEIN, LLC
By: s/Andrew W. Callahan
Andrew W. Callahan, #52421
Attorneys for Defendants
CERTIFICATE OF ELECTRONIC FILING
The undersigned hereby certifies that a true and correct copy of the foregoing
DEFENDANTS’ SECOND UNOPPOSED MOTION FOR ENLARGEMENT OF TIME
TO FILE RESPONSIVE PLEADING was filed via the Colorado Courts E-Filing System and
served this 23
rd
day of March, 2020, on the following:
Stacy Lynne
305 West Magnolia Street #282
Fort Collins, CO 80521
Served via email to stacy_lynne@comcast.net & U.S. Mail.
s/ Jody L. Minch
[The original certificate of electronic filing signed by Jody L. Minch is on file at Wick &
Trautwein, LLC)