Free Motion for Leave - District Court of Colorado - Colorado

Case 1:04-cv-00791-WDM-BNB

Document 125

Filed 05/23/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-00791-WDM-BNB

STEPHEN H. ADAMS, Plaintiff, v. MICHAEL GASKILL, Aurora Police Department, CITY OF AURORA, COLORADO, a municipal corporation, Defendants. ______________________________________________________________________________ MOTION FOR LEAVE OF COURT TO TAKE DEPOSITION OF PLAINTIFF

COME NOW, Defendants above named, by and through their attorneys of record, and hereby respectfully move this Honorable Court for an Order pursuant to Fed.R.Civ.P. 30(a)(2) permitting the deposition of the Plaintiff, currently incarcerated, and as GROUNDS THEREFOR WOULD SHOW: 1. The Plaintiff herein is presently incarcerated at the Colorado Territorial Correctional

Facility, Canon City, Colorado. 3. The Defendants have made arrangements with the Correctional facility for the taking

of the Plaintiff's deposition in this matter and have scheduled the same for Tuesday, June 5, 2007, at 1:00 p.m., at the Correctional Facility in Canon City, Colorado. 3. As required by Local Rule 7.1, counsel for the Defendants is unable to confer with

Plaintiff as Plaintiff is pro se and remains incarcerated and therefore, unable to accept telephone calls

Case 1:04-cv-00791-WDM-BNB

Document 125

Filed 05/23/2007

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to discuss this Motion. WHEREFORE, Defendants respectfully request this Honorable Court grant them leave to take the deposition of the Plaintiff, currently an incarcerated party, on June 5, 2007. DATED this 24th day of May, 2007. Respectfully submitted, BRUNO, COLIN, JEWELL & LOWE, P.C. s/Michael T. Lowe Michael T. Lowe 1560 Broadway, Suite 1099 Denver, Colorado 80202-5143 Telephone: (303) 831-1099 [email protected] Counsel for Defendant Gaskill Charles Richardson, Esq. Peter Morales. Esq. AURORA CITY ATTORNEY'S OFFICE 15151 E. Alameda Parkway Aurora, Colorado 80012-1553 Telephone: (303) 739-7030 [email protected] Counsel for Defendant the City of Aurora

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Case 1:04-cv-00791-WDM-BNB

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CERTIFICATE OF SERVICE I hereby certify that on the 24th day of May, 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: Charles Richardson, Esq. Peter Morales. Esq. AURORA CITY ATTORNEY'S OFFICE 15151 E. Alameda Parkway Aurora, Colorado 80012-1553 [email protected] and by U.S. Mails, postage prepaid to: Stephen H. Adams Reg No 86319 Unit: 7 C.T.C.F. P.O. Box 1010 Canon City, CO 81215 s/Linda E.Yeros __________________________________________

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