Free Response to Motion - District Court of Colorado - Colorado

Case 1:04-cv-01067-MSK-CBS

Document 178

Filed 09/14/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

04-cv-1067-REB-CBS

WILLIAM R. CADORNA, Plaintiff, v. THE CITY AND COUNTY OF DENVER, COLORADO, a Municipal Corporation, Defendant.

PLAINTIFF' R S O S T D F N A TSMO I NT P S P S EP N E O EE D N' TO O O T ONE ENTRY OF JUDGMENT

Pa t Wia R C d ra( lni ) lni l m . a on " a t "hereby R s o d t D fn a t A g s if l f i P if f e p n ' o ee d n' u u t s s 30, 2006 Motion to Postpone Entry of Judgment: 1. Defendant is well experienced in federal court procedures. It had good

reason to expect an adverse verdict well before trial. Defendant undoubtedly planned, as is its arrogant wont, to persist in denying Plaintiff justice through abuse of its practically unlimited litigation budget if adverse judgment were entered. 2. Defendant knew of the need to order transcripts on the afternoon of June

29, 2006, and did indeed engage, in the person of the very able head of its Employment Law Division, in extended conversation that afternoon with the Court Reporter concerning production of transcripts.

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Case 1:04-cv-01067-MSK-CBS

Document 178

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3.

In just over two months, it will have been four years since Defendant

forced Plaintiff into a long, nightmarish slog through a vast muck of incompetence and deceit in order to regain his dignity, honor and good name. 4. To date, Defendant has persisted in its unlawful and retaliatory abuse of

Plaintiff with virtual impunity. Given the complete lack of accountability of the officials responsible for this travesty, Plaintiff fully expects that this matter will drag on for years. 5. Plaintiff takes considerable comfort in the k o l g ta tej y v ri n we e h th u ' ed t d rs c

i ta k t tiC ut to g t l arwn o tei u s ob d c e b tej y s h n s o h o rs h u hf n r i fh s e t e e i d y h u , , s ' u o g s d r c mp tlu a s ib .T ev ri i" n ynteb n "a dwl n go , i o l e n saa l h ed t mo e i h a k, n io l rw wt e y l e cs l y h interest, as any post-trial or appellate proceedings unfold. Even were Defendant able to raise Daniel Webster and Clarence Darrow from the grave to represent it, it could not ra o a lh p t u d tej y v ri tru hj ia n li t n e s n b o e o n o h u ' ed tho g u c l ui ai . y rs c di lc o f 6. With the passage of time and benefit of considerable reflection, Plaintiff

and his counsel have come to fully appreciate the extent to which (though it seemed at times that this Court was completely hostile to Plaintiff and his counsel, and was determined to do everything in its power to deny Plaintiff a fair trial) this Court did Plaintiff and his counsel a huge favor by thoughtfully and carefully presiding over the po e d g ,r i h r" nPa t '" mb n t u " o n e i u gj yn t co s rc e i s "d g ed o lnis r u co s c u s ls i u i r t n n in if a f i , s n r su i that were very conservative, and ensuring that only lni'mo t n saa l c i Pa t s s u a s ib lms if f l e a w r d c e b tej y A ted e te u o tiC ut s i, u e n nlws , ee e i d y h u . s h i c rs l fh o rs tc b t mi t i d r r t s ' rt e y e handling of the trial, Defendant has no grounds for appeal. Of course, Defendant, being Defendant, will appeal, and appeal, and appeal some more.

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Case 1:04-cv-01067-MSK-CBS

Document 178

Filed 09/14/2006

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7.

Plaintiff is confident that, just as the jury was wisely immune to

D fn a t d c pi ,h H n rb C ut id e ey i i i p w roe s r ee d n' e e t n ti o oa l o rwl o v rt n n t o e t n ue s o s e l hg s that Defendant will not unnecessarily delay the just compensation so long denied him. WHEREFORE, Plaintiff respectfully requests that this Honorable Court deny Defendant'Moi t P s o eE t o J d me t s t n o o t n nr f u g n. o p y DATED this 14th day of September, 2006. Respectfully submitted, /S/

Mark E. Brennan

Mark E. Brennan, P.C. P.O. Box 2556 Centennial, CO. 80161-2556 (303) 552-9394 (office) (303) 797-7687 (cell) [email protected] Attorney for Plaintiff CERTIFICATE OF SERVICE The undersigned hereby certifies that, on this 14th day of September, 2006, he served a copy of the foregoing Response to Motion to Postpone Entry of Judgment on the following person(s) via electronic mail: Jack Wesoky, Esq. Chris Lujan, Esq. 210 W. Colfax, Dept 1108 Denver, CO. 80202

S/

Mark E. Brennan

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