Free Motion to Withdraw as Attorney - District Court of Colorado - Colorado

Case 1:01-cv-02313-JLK

Document 112

Filed 06/17/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil action No. 01-cv-02313-JLK-CBS

GLN COMPLIANCE GROUP, INC., Plaintiff, v. UNITED AIRLINES, INC., d/b/a UNITED BIZJET HOLDINGS, BIZJET CHARTERS, INC., AND BIZJET SERVICES, INC., and JONATHAN ROSS Defendants, v. GERALD NAEKEL, Third- Party Defendant. _____________________________________________________________________________ MOTION TO WITHDRAW AS ATTORNEYS FOR PLAINTIFF GLN COMPLIANCE GROUP, INC. AND THIRD-PARTY DEFENDANT GERALD NAEKEL ______________________________________________________________________________

Elizabeth A. Starrs and Daniel A. Wartell, of the law firm Starrs Mihm & Caschette LLP, move to withdraw as counsel for GLN Compliance Group, Inc. ("GLN") and Gerald Naekel pursuant to D.C.COLO.LCivR 83.3(D). In support of this Motion, the undersigned counsel states the following: 1. The Court entered a Stipulated Scheduling and Discovery Order on February 26,

2008. The parties are currently engaged in discovery. This matter is not set for trial. 1

Case 1:01-cv-02313-JLK

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2.

Good cause exists to permit the undersigned counsel to withdraw as counsel of

record for GLN and Gerald Naekel because the attorney-client relationship has irretrievably broken down. 3. Undersigned counsel has filed and served GLN and Gerald Naekel with a Notice of

Withdrawal advising them of their responsibilities to comply with all court orders and time limitations established by any applicable rules. CERTIFICATION PURSUANT TO D.C.COLO.LCivR 7.1(A) The undersigned certifies that she has conferred with counsel for the Defendant and they take no position on this Motion. Mr. Naekel and GLN Compliance Group, Inc. will object to this Motion. WHEREFORE, for the above-stated reasons, undersigned counsel respectfully requests that the Court enter an Order permitting Elizabeth A. Starrs and Daniel A. Wartell of Starrs Mihm & Caschette to withdraw as counsel of record for GLN and Gerald Naekel. Dated: June 17, 2008 s/ Elizabeth A. Starrs Elizabeth A. Starrs Daniel A. Wartell STARRS MIHM & CASCHETTE LLP 707 Seventeenth Street, Suite 2600 Denver, CO 80202 Telephone: 303-592-5900 Facsimile: 303-592-5910 [email protected] [email protected] Attorneys for GLN Compliance, Inc. and Gerald Naekel

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Case 1:01-cv-02313-JLK

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CERTIFICATE OF MAILING The undersigned hereby certifies that on June 17, 2008 a true and correct copy of the foregoing MOTION TO WITHDRAW AS ATTORNEYS FOR GLN COMPLIANCE GROUP, INC. AND GERALD NAEKEL was served via CM/ECF and via U.S. Mail and email to the following: VIA CM/ECF Stephen D. Gurr, Esq. Amy Arlander, Esq. Kamlet Shepherd & Reichert LLP 1515 Arapahoe Street, Tower 1, Suite 1600 Denver, Colorado 80202 VIA U.S. MAIL AND ELECTRONIC MAIL GLN Compliance Group, Inc. 12835 East Arapahoe Road Tower ­ 1, Suite 600 Centennial, CO 80112 VIA U.S. MAIL AND ELECTRONIC MAIL Mr. Gerald Naekel 12835 East Arapahoe Road Tower ­ 1, Suite 600 Centennial, CO 80112 [email protected]

/s/ Melissa Sergent Melissa Sergent

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