Free Motion for Leave - District Court of Colorado - Colorado

Case 1:01-cv-01690-WDM-MJW

Document 132

Filed 11/04/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISCTRICT OF COLORADO Civil Action No. 01-WM-01690 (MJW) CONAIL CROSS, Plaintiff, v. THE HOME DEPOT Defendant. REQUEST FOR TELEPHONIC APPEARANCE

This court has scheduled a final pre-trial conference in this case for November 29, 2005 at 11:00 a.m. Plaintiff's counsel's primary business is located in Los Angeles, California. In addition to the trial of the case herein, set for December 5, 2005, Plaintiff's counsel is currently set to be engaged in trial in San Luis Obispo, California commencing on November 30, 2005. The case name is In re: James and Marguerite Sullivan Trust of 1987, Case No. PR050044. Therefore, traveling to Denver, Colorado for the pre-trial conference will be extremely difficult and costly. Such difficulty and cost would be greatly reduced if Plaintiff's counsel were to appear by phone. Daniel E. Friesen, counsel for Defendant, has represented to the undersigned counsel for Plaintiff that he does not opposed this request. Plaintiff's counsel is further informed and believes that none of the parties will be prejudiced if Mr. Hess appears by phone.

(1)

Case 1:01-cv-01690-WDM-MJW

Document 132

Filed 11/04/2005

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Wherefore, Plaintiff's counsel respectfully requests that he be allowed to appear by phone when this matter is called on November 29, 2005.

DATED: November 4, 2005

s/William R. Hess WILLIAM R. HESS 5455 Wilshire Blvd. Suite 2100 Los Angeles, CA 90036 (323)931-7330 (fax)(323)931-7990 E-mail:[email protected] Attorney for Plaintiff

(2)

Case 1:01-cv-01690-WDM-MJW

Document 132

Filed 11/04/2005

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UNITED STATES DISTRICT COURT FOR THE DISCTRICT OF COLORADO CERTIFICATE OF SERVICE I hereby certify that on November 4, 2005 I electronically filed the foregoing Request for Telephonic Appearance with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following email addresses:

· ·

Daniel Ernest Friesen [email protected] William R. Hess [email protected]

s/William R. Hess WILLIAM R. HESS 5455 Wilshire Blvd. Suite 2100 Los Angeles, CA 90036 (323)931-7330 (fax)(323)931-7990 E-mail:[email protected] Attorney for Plaintiff

(3)

Case 1:01-cv-01690-WDM-MJW

Document 132

Filed 11/04/2005

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