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Motion for Continuance of Trial and Stay of Discovery Deadlines
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Motion for Continuance of Trial and Stay of Discovery Deadlines
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7/15/2010 1:20:40 PM
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Water Supply Protection
Description
Case No. 00CW259 Vail RICD and Case No. 00CW281 Breckenridge RICD
State
CO
Basin
Colorado Mainstem
Water Division
5
Date
11/14/2001
Author
Ken Salazar, John J. Cyran
Title
Motion for Continuance of Trial and Stay of Discovery Deadlines
Water Supply Pro - Doc Type
Court Documents
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decision likely will be appealed by the losing party pending the Supreme Court's <br />decision, and may result in further remand to this Court for further proceedings consistent <br />with the Supreme Court's decision. Such an appeal and remand clearly would result in <br />significant additional expenses for all the litigants. The parties would be forced to order <br />transcripts, prepare briefs, and schedule arguments and hearings before the Supreme <br />Court and this Court. If this Court were to continue trial until the Supreme Court has <br />clarified its ruling in City of Fort Collins, however, an appeal by the losing party likely <br />would be unnecessary, and such additional expenses need not be incurred. <br />E. A Continuance and Stay Will Not Cause Prejudice to the Applicants. <br />In addition to providing for resolution of an important legal issue, promoting <br />judicial economy, and conserving the parties' resources, granting a continuance will cause <br />no prejudice to the Applicants. The Applicants have secured their appropriation date by <br />filing their applications. Continuing trial in these matters for that minimal amount of <br />time necessary for the Supreme Court to issue its decision will not jeopardize that <br />appropriation date. <br />Nor will the Applicants suffer any other prejudice. The Objectors are unaware of <br />(and the Applicants' initial disclosures do not identify) any evidence relied upon by the <br />Applicants that would be unavailable if the trial date were continued for such time as is <br />necessary for the Supreme Court to issue its final decision. <br />Granting a continuance also would not injure the Applicants in their utilization of <br />their whitewater courses. The Applicants have completed construction of those courses, <br />and the courses currently are in use. <br />If anything, the Applicants will benefit from a continuance. The Applicants, like <br />the Objectors, will not be required to incur expense trying issues that will soon be <br />resolved by the Supreme Court. The Applicants will not be required to appeal matters <br />that they believe are decided in a manner inconsistent with the Supreme Court's City of <br />Fort Collins ruling, nor face the expense of a remand if this Court's decision is in some <br />manner inconsistent with the final Supreme Court ruling. The Applicants will enjoy <br />certainty, as will the Objectors and the water court, from the finality that a Supreme Court <br />decision will afford. <br />F. A Continuance and Stay Will Be of Moderate Duration. <br />Finally, the Court should exercise its discretion and continue the trial in these <br />matters .because any such continuance would be of limited duration. Any continuance <br />would be limited to that time necessary for the Supreme Court to decide the CWCB's <br />appeal in Case No. 01 SA252. Currently, the Record on Appeal is due in the Supreme <br />Court on or before November 29, 2001. Thus, the briefing should be completed by <br />
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