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052 PSCo Response to COB Unopposed Mtn for Ext of time to Respond to PSCo Mtn for Protective Order1 DISTRICT COURT, BOULDER COUNTY, COLORADO Court Address: 1777 6th Street, Boulder Colorado 80302 303-441-3750 _________________________________________________ Petitioner: THE CITY OF BOULDER, a Colorado Home Rule City, v. Respondent: PUBLIC SERVICE COMPANY OF COLORADO, a Colorado Corporation, d/b/a XCEL ENERGY; MORGAN GUARANTY TRUST COMPANY OF NEW YORK; and PAUL WEISSMANN, in his official capacity as Treasurer of Boulder County. _________________________________________________ Attorneys for Respondent, Public Service Company of Colorado John R. Sperber, Atty. Reg. No. 22073 Sarah M. Kellner, Atty. Reg. No. 38111 FAEGRE DRINKER BIDDLE & REATH LLP 1144 Fifteenth Street, Suite 3400 Denver, Colorado 80202 Telephone: (303) 607-3500 Fax: (303) 607-3600 jack.sperber@faegredrinker.com sarah.kellner@faegredrinker.com COURT USE ONLY __________________________ Case Number: 19 CV 30637 Division: 5 RESPONSE TO UNOPPOSED MOTION FOR EXTENSION OF TIME Respondent, Public Service Company of Colorado (“Respondent” or “PSCo”), through its undersigned counsel, respectfully files this Response to the City of Boulder’s (“Boulder” or “City”) Unopposed Motion for Extension of Time to Respond to Public Service Company of Colorado’s Motion for Protective Order. DATE FILED: April 22, 2020 2:26 PM FILING ID: CF69B0BBEA4D7 CASE NUMBER: 2019CV30637 2 RESPONSE 1. As stated in Boulder’s conferral, PSCo has no objection to Boulder’s request for an extension of time to Respond to PSCo’s Motion for Protective Order. 2. While PSCo disagrees with some of the City’s representations about the underlying communications between the parties and what transpired leading up to PSCo filing its motion for protective order (in particular, Boulder’s claim that PSCo agreed to such discovery) such issues can and will be addressed when the Motion for Protective Order is taken up again after the appeal if Boulder’s motion for extension of time is granted. 3. PSCo also has no objection to Boulder’s additional requested relief about setting the attorney fee hearing after the Motion for Protective Order is decided and any discovery that might be allowed is complete. Boulder’s request in its Motion is not the same as the proposal Boulder made in its conferral or PSCo’s counsel would have agreed to it then. Respectfully submitted this 22nd day of April 2020. FAEGRE DRINKER BIDDLE & REATH LLP s/ John R. Sperber John R. Sperber, Atty. Reg. No. 22073 Attorneys for Respondent Public Service Company of Colorado 3 CERTIFICATE OF SERVICE The undersigned certifies that on April 22, 2020, a copy of the foregoing RESPONSE TO MOTION FOR EXTENSION OF TIME was served on the following by the methods listed below: Attorneys for Petitioner, City of Boulder: Office of the Boulder City Attorney Thomas A. Carr Kathleen E. Haddock P.O. Box 791 Boulder, CO 80306 carrt@bouldercolorado.gov haddockk@bouldercolorado.gov ( ) First Class Mail ( ) Hand Delivery ( ) Overnight Delivery (X ) CCES ( ) E-Mail Hamre, Rodriguez, Ostrander & Dingess, PC Donald M. Ostrander Richard F. Rodriguez 3600 S. Yosemite Street, Suite 500 Denver, CO 80237 dostrander@hrodlaw.com rrodriguez@hrodlaw.com ( ) First Class Mail ( ) Hand Delivery ( ) Personal Service ( ) Overnight Delivery (X ) CCES ( ) E-Mail /s/ Veronnica Thomas Veronica Thomas, Legal Administrative Assistant