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

Case 1:01-cv-01315-REB-CBS

Document 139

Filed 04/23/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 01-cv-01315-REB-CBS LEONARD BALDAUF, Plaintiff,
v.

JOHN HYATT, et. al. Defendants.

MOTION TO WITHDRAW

The undersigned counsel, Gillian Dale, attorney for Defendants John Hyatt, Robert Fahey, Betty Fulton, Paul Carreras, Connie Davis, Ken Maestas, Joseph Garcia, and David Archuleta hereby moves this Court, pursuant to D.C.COLO.LCivR 83.3(D), to be allowed to withdraw as counsel for Defendants, and as grounds therefore states as follows: 1. Gillian Dale, an associate with the law firm of Hall & Evans, LLC,

represented Defendants in this matter along with Andrew D. Ringel, a member with Hall & Evans, LLC. Ms. Dale is terminating her employment with Hall & Evans, LLC,

effective April 27, 2007, and will be joining the law firm of Hale-Friesen LLP. 2. Mr. Ringel continues to represent Defendants in this matter. Defendants

have been notified of the withdrawal of Ms. Dale and wish to continue to be represented by Mr. Ringel. Because Defendants continue to have representation from Mr. Ringel in

Case 1:01-cv-01315-REB-CBS

Document 139

Filed 04/23/2007

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this matter, the requirement of notifying Defendants that they are personally responsible for compliance with all court deadlines does not apply. 3. As Ms. Dale is no longer associated with Hall & Evans, LLC, and as Mr.

Ringel continues to represent Defendants, Ms. Dale respectfully requests that the Court enter an order permitting her to withdraw from this case. 4. Pursuant to D.C.COLO.LCivR 7.1(A), the undersigned counsel contacted

Plaintiff's attorney, Dennis Hartley, via e-mail on April 19, 2007, but did not receive a response prior to filing this motion. WHEREFORE, the undersigned counsel respectfully requests that the Court enter an Order permitting her to withdraw as counsel for Defendants. Dated this 23rd day of April, 2007. Respectfully submitted,

s/ Gillian Dale Andrew D. Ringel, Esq. Gillian Dale, Esq. Hall & Evans, L.L.C. 1125 17th Street, Suite 600 Denver, CO 80202-2052 [email protected] [email protected] 303-628-3300 phone 303-628-3368 fax ATTORNEYS FOR DEFENDANTS JOHN HYATT, ROBERT FAHEY, BETTY FULTON, PAUL CARRERAS, CONNIE DAVIS, KEN MAESTAS, JOSEPH GARCIA, AND DAVID ARCHULETA

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Case 1:01-cv-01315-REB-CBS

Document 139

Filed 04/23/2007

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CERTIFICATE OF SERVICE (CM/ECF) I HEREBY CERTIFY that on the 23rd day of April, 2007, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Dennis W. Hartley Dennis W. Hartley, P.C. 1749 South 8th Street, Suite 5 Colorado Springs, Colorado 80906 [email protected] and hereby certify that I have mailed or served the document or paper to the following non-CM/ECF participant in the manner (mail, hand delivery, etc.) indicated by the non-participant's name: None

s/ Denise Gutierrez, Secretary Andrew D. Ringel, Esq. Gillian Dale, Esq. Hall & Evans, L.L.C. 1125 17th Street, Suite 600 Denver, Colorado 80202-2052 Phone: 303-628-3300 Fax: 303-293-3238 [email protected] [email protected] ATTORNEYS FOR DEFENDANTS

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