Free Motion to Withdraw - District Court of Colorado - Colorado

Case 1:01-cv-02313-JLK

Document 75-2

Filed 05/25/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil action No. 01-K-2313 (CBS) GLN COMPLIANCE, INC., Plaintiff, v. UNITED AIRLINES, INC., d/b/a UNITED BIZJET HOLDINGS, BIZJET CHARTERS, INC., and BIZJET SERVICES, INC., and JONATHAN ROSS, Defendants.

NOTIFICATION CERTIFICATE

Richard O. Schroeder, counsel for Plaintiff GLN Compliance Group, Inc. provides this Notice of Withdrawal as attorney of record and affirms to the Court, the client and all other attorneys and parties of record: TO: Gerald Naekel GLN Compliance Group, Inc. 12835 E Arapahoe Rd Ste 1-600 Centennial CO 80112-6726 Work: 303.925.1491

Please take notice of the following: 1. You have requested that the undersigned withdraw from this matter, and Richard

O. Schroeder has requested permission to withdraw as your attorney in this action. 2. The United States District Court for the District of Colorado retains jurisdiction

over the case and you.

Case 1:01-cv-02313-JLK

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Filed 05/25/2007

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3.

You have the burden of keeping the Court informed where notices, pleadings, and

other papers may be served on you. 4. You have an obligation to prepare for any hearings, if one should be scheduled, or

hire another attorney to prepare for the hearing, if one is scheduled. 5. GLN Compliance Group, Inc. cannot appear without counsel admitted to practice

before this court, and absent prompt appearance of substitute counsel, pleadings, motions, and other papers may be stricken, and default judgment or other sanctions may be imposed against the entity. 6. 7. Your case is not set for trial. The withdrawal of the undersigned counsel will not affect the holding of these

proceedings. 8. 9. 10. Service of process may be served upon you at your last known address. You have the right to object within 15 days of the date of this notice. Undersigned counsel certifies that the above notification requirements have been

met by letter and by service of this document. The client's last known address and telephone numbers are reflected above.

Dated: 25 May 2007.

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Case 1:01-cv-02313-JLK

Document 75-2

Filed 05/25/2007

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Respectfully Submitted

s/ Richard O. Schroeder Richard O. Schroeder, #27616 Richard O. Schroeder, PC 8191 Southpark Lane, Suite 211 Littleton, Colorado 80120 Telephone: 303.683.3691 Facsimile: 303.683.4493 E-mail: [email protected] Attorney for Plaintiff

CERTIFICATE OF SERVICE I certify that I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to: Mark Barnes, Esq. Brownstein Hyatt & Farber, P.C. 410 17th Street, 22nd Flr. Denver, CO 80202 [email protected] Via First Class Mail Only Gerald Naekel GLN Compliance Group 12835 E Arapahoe Rd Ste 1-600 Centennial CO 80112-6726 Stephen D. Gurr, Esq. Elzi, Pringle & Gurr 950 17th Street, Suite 1875 Denver, CO 80202 [email protected] Courtesy Copy Via Email Micha E. Marcus, Esq. Kirkland & Ellis, LLP 200 E Randolph Dr Chicago, IL 60601 [email protected]

Dated: 25 May 2007 s/ Richard O. Schroeder Richard O. Schroeder, #27616 Richard O. Schroeder, PC 8191 Southpark Lane, Suite 211 Littleton, Colorado 80120 Telephone: 303.683.3691 Facsimile: 303.683.4493 E-mail: [email protected] Attorney for Plaintiff

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