Object Time Unemployment federal
- Date
- 2025-03-07
Summary
Plaintiff's Objection to Defendant's Extension, filed April 10, 2025 as Document 31 in Joshua Abrams v. Division of Unemployment Insurance, Case No. 1:24-cv-03390-RMR, in the U.S. District Court for the District of Colorado, by the plaintiff pro se. The objection opposes the defendants' motion for more time, until April 28, 2025, to respond to the Amended Complaint, and asks that the April 14, 2025 deadline be enforced. It states that service was completed on March 24, 2025, correcting an earlier reference to March 7, 2025, and argues that the defendants missed the April 7, 2025 deadline set by the Court's March 7, 2025 Order to respond to the Emergency Motion for Injunctive Relief. It asks the Court to order an immediate response and to rule on pending motions, including a Request for Court-Appointed Counsel.
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Case No. 1:24-cv-03390-RMR Document 31 filed 04/10/25 USDC Colorado pg 1
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The United States District Court District of Colorado
FILED
901 19th St, Denver, CO 80294 | (303) 844-3433 UNITED STATES DISTRICT COURT
DENVER, COLORADO
Plaintiff: Joshua Abrams 9:38 am, Apr 10, 2025
v. JEFFREY P. COLWELL, CLERK
Defendant(s): Division of Unemployment Insurance,
251 E 12th Ave Denver, CO 80203 ▲COURT USE ONLY▲
Joshua Abrams, Pro Se | abramslive@gmail.com |609-968-9360 Case Number:
1881 E 112th Pl, Northglenn Colorado 80233 1:24-cv-03390-RMR
Division: Courtroom
Plaintiff’s Objection to Defendant’s Extension
Plaintiff Joshua Abrams submits this objection to Defendants’ Motion for Extension of Time to
Respond to the Amended Complaint, and further requests that the Court act promptly on
Plaintiff’s previously filed Emergency Motion for Injunctive Relief and related motions.
1. Plaintiff acknowledges that a prior filing mistakenly referenced a March 7, 2025 service
date, based on a Clerk’s Certificate of Service to the U.S. Marshals. Defendants have
since confirmed that formal service was completed on March 24, 2025, and Plaintiff
does not dispute this corrected timeline.
2. Despite the service occurring on March 24, 2025, Defendants were subject to this Court’s
March 7, 2025 Order requiring a response to Plaintiff’s Emergency Motion for
Injunctive Relief within 14 days of service. That deadline expired on April 7, 2025. As
of the date of this filing, April 10, 2025, no response to the Emergency Motion has been
submitted, in direct violation of this Court’s order.
Case No. 1:24-cv-03390-RMR Document 31 filed 04/10/25 USDC Colorado pg 2
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3. Defendants now request additional time, until April 28, 2025, to respond to the Amended
Complaint. Plaintiff respectfully opposes this extension. The Amended Complaint has
been on the docket since February 7, 2025, and Defendants, who are represented by
multiple attorneys and counsel and supported by institutional resources have had ample
time and resources to review and begin preparing a response. The justification that the
complaint is lengthy or complex is unpersuasive at under 40 pages.
4. The deadline for Defendants to respond to the Amended Complaint, currently set for
April 14, 2025, should remain firmly enforced, particularly in light of their prior failure
to meet the Court-ordered April 7, 2025 deadline to respond to Plaintiff’s Emergency
Motion for Injunctive Relief.
5. No party actively engaged in ongoing constitutional violations, especially one
represented by experienced legal counsel and supported by institutional resources should
be afforded leniency or exceptions to standard procedural rules. Allowing such delays
and pandering to their convenience only compounds the irreparable harm suffered by
thousands of Colorado residents, many of whom face eviction, food insecurity, loss of
access to medicine, and disruption of essential life needs due to the systemic failures at
issue in this case. Defendants’ delay in responding to a Court-ordered emergency motion,
followed by a request for additional time, reflects misplaced priorities.
Plaintiff respectfully asks the Court to take the following actions to preserve the integrity of its
prior orders and to ensure the urgent issues raised are addressed without further delay:
● Deny Defendants’ Motion for Extension of Time to respond to the Amended Complaint, given
the time already available to Defendants and the ongoing emergency nature of this case;
Case No. 1:24-cv-03390-RMR Document 31 filed 04/10/25 USDC Colorado pg 3
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● Order an immediate response from Defendants to Plaintiff’s Emergency Motion for Injunctive
Relief, as required by the Court’s March 7, 2025 Order — a deadline which Defendants openly
missed by at least three (3) days, regardless of Plaintiff’s earlier misinterpretation of the service
date;
● Rule on or schedule a hearing for Plaintiff’s previously filed motions, including the Request
for Court-Appointed Counsel and earlier requested status conference all of which remain pending
and urgent in light of ongoing constitutional harms;
The urgency of this case cannot be overstated. Defendants should not be afforded additional time
to strategize how to dismiss or delay while constitutional rights are actively being violated and
human lives are affected. Plaintiff urges the Court to prioritize immediate intervention and
enforcement of its prior orders.
Respectfully submitted,
________________________________________
Date: 04-10-2025 | ❑Petitioner/Plaintiff
Joshua Abrams, Pro Se
CERTIFICATE OF SERVICE
I certify that on 04-10-2025 a true and accurate copy of the Defendant was served on the other party by:
X_E-filed, lauren.davison@coag.gov & Stephen.woolsey@coag.gov
__________________________________________
❑Petitioner/Plaintiff
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