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HomeMy WebLinkAbout2018CV3204 - Lori Frank V. City Of Fort Collins, Terence F. Jones And Jerome Schiager - 011 - Defendant Schiager's Unopposed Motion For Extension Of Time To File Response To ComplaintIN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 18-cv-03204-NRN LORI FRANK, Plaintiff, v. CITY OF FORT COLLINS, a municipality; TERENCE F. JONES, former Interim Chief of Police, in his individual capacity; and JEROME SCHIAGER, former Deputy Chief of Police, in his individual capacity, Defendants. _________________________________________________ _____________________ DEFENDANT SCHIAGER’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO COMPLAINT _______________________________________________________________________ Defendant JEROME SCHIAGER, former Deputy Chief of Police, hereby moves this Court for an order extending the time through and including January 31, 2019, to file an answer, motion, or other responsive pleading and, as grounds therefor, states the following: CERTIFICATION Pursuant to D.C.COLO.LCivR 7.1(a), Defendant Schiager’s counsel has conferred with Plaintiff’s counsel. Defendant Schiager’s counsel certifies that Plaintiff has no objection to this motion. Pursuant to D.C.COLO.LCivR 6.1(c), Defendant Schiager’s counsel is providing a copy of this motion to his client, as set forth in the certificate of service below. Case 1:18-cv-03204-NRN Document 11 Filed 01/03/19 USDC Colorado Page 1 of 3 MOTION 1. Defendant Schiager’s answer or other response is purportedly due on January 4, 2019. 2. Undersigned counsel confirmed on January 3, 2019, that he has been retained to defend Mr. Schiager. He was able to speak with Mr. Schiager for the first time on January 3. 3. Undersigned counsel needs to meet in person with Mr. Schiager and obtain materials relating to this matter to prepare an appropriate defense. 4. Defendant Schiager requests an extension of time through and including January 31, 2019, in which to file an answer, motion, or other responsive pleading. WHEREFORE, Defendant Schiager requests that the Court issue an order granting him an extension of time through and including January 31, 2019, in which to file an answer, motion, or other responsive pleading in this action. Respectfully submitted, Date: 01/03/19 s/ David R. DeMuro David R. DeMuro VAUGHAN & DeMURO 720 South Colorado Boulevard Penthouse, North Tower Denver, CO 80246 303-837-9200 (phone) ddemuro@vaughandemuro.com (e-mail) ATTORNEY FOR DEFENDANT SCHIAGER 2 Case 1:18-cv-03204-NRN Document 11 Filed 01/03/19 USDC Colorado Page 2 of 3 CERTIFICATE OF SERVICE I hereby certify that on this 3rd day of January, 2019, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Jennifer Robinson jrobinson@raemployment.com Cathy Havener Greer cgreer@warllc.com; bmccall@warllc.com; pcallies@warllc.com and I hereby certify that the foregoing is being served via private email address on the following: Jerome Schiager [by email] s/ David R. DeMuro David R. DeMuro 3 Case 1:18-cv-03204-NRN Document 11 Filed 01/03/19 USDC Colorado Page 3 of 3