HomeMy WebLinkAbout2020CV116 - STACY LYNNE V. CITY OF FORT COLLINS, CITY MANAGER, CITY ATTORNEY CARRIE DAGGETT, RACHEL ASKELAND AND KAREN BURKE - 005 - DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE RESPONSIVE PLEADINGDISTRICT 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:
CITY OF FORT COLLINS: City Manager City
Attorney Carrie Daggett, Rachel Askeland (Acting
Records Custodian), Karen Burke (Records Custodian)
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 116
Courtroom: 3C
DEFENDANTS’ UNOPPOSED MOTION FOR ENLARGEMENT
OF TIME TO FILE RESPONSIVE PLEADING
COMES NOW, the Defendants, the City of Fort Collins, Carrie Daggett, Rachel
Askeland and Karen Burke, by and through counsel, Wick & Trautwein, LLC, and respectfully
submit the following unopposed motion for enlargement of time for the defendants to file their
responsive pleadings to the Plaintiff’s 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 is not opposed to the relief
requested herein.
2. Defendants’ were served with the Complaint on or about February 14, 2020, which
would make their responsive pleading due on March 6, 2020. Defendants seek an enlargement
of time up to and including March 27, 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.
DATE FILED: March 2, 2020 2:00 PM
FILING ID: F634186D6112B
CASE NUMBER: 2020CV116
2
Respectfully submitted this 2
nd
day of March, 2020.
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’ UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE
RESPONSIVE PLEADING was filed via the Colorado Courts E-Filing System and served this
2
nd
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)